document title - cntw.nhs.uk

Document title Media Policy

Reference number CNTW(HR)24

Lead officer John Lawlor

Chief Executive

Author(s)

(name and designation)

Adele Joicey

Head of Communications

Ratified by Business Delivery Group

Date ratified February 2021

Implementation date February 2021

Date of full implementation

February 2021

Review date February 2024

Version number V04

Review and amendment log

Version Type of change

Date Description of change

This policy supersedes the following Policy which must now be destroyed:

Document number Title

CNTW(HR)24 – V03.2 Social Media Policy

CNTW(HR)24

Social Media Policy

Section Contents Page No.

1 Introduction 1

2 Purpose 2

3 Duties, accountabilities and responsibilities 2

4 Definition of terms used 4

5 The Trusts work with the Media 4

6 VIPs visits on Trust Premises 5

7 Protocol for Media enquiries 5

8 Private use of social media 7

9 Professional use of social media 8

10 Identification of Stakeholders 9

11 Training 9

12 Implementation 9

13 Monitoring and Compliance 9

14 Fair Blame 10

15 Fraud, Bribery and Corruption 10

16 Equality and Diversity Assessment 10

17 Associated Documents 10

Standard appendices – attached to policy

A Equality analysis screening toolkit 11

B Training checklist and training needs analysis 13

C Audit monitoring tool 16

D Policy notification record sheet - click here

Appendices – listed separate to Policy

Document No: Description

Appendix 1 Think Social Media

https://www.cntw.nhs.uk/about/policies/appendix-d-policy-notification-record-sheet/

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1 Cumbria, Northumberland, Tyne and Wear NHS Foundation Trust CNTW(HR)24 - Media Policy – V04-Feb 2021

1 Introduction 1.1 The media plays an important role in sharing information about the Trust’s

services and in making sure that both successes and challenges are fairly and accurately reported to the populations we serve.

1.2 Managing the reputation of the Trust is very important and any staff who are approached by the media should immediately refer the journalist to the Communications Team who can be contacted 24/7 via switchboard.

1.3 In doing so, staff should follow the same behavioural standards as they would in their everyday roles and abide by their legal and ethical duties to protect service users and colleague confidentiality in line with the ‘Caldicott principles’.

1.4 Cumbria, Northumberland, Tyne and Wear NHS Foundation Trust (the

Trust/CNTW) endeavours to make best use of media, which includes print media (newspapers and magazines), broadcast media (TV, Radio), internet media (website, social networks such as Facebook, LinkedIn, Twitter and YouTube) to engage with service users, staff and other stakeholders.

1.5 These professional interactions are encouraged by the Trust and their use is

likely to be further extended as new communications channels become available.

1.6 Social media is the term commonly used for computer-based technology such

as websites and applications which enable users to create and share content or to participate in social networking. Such technologies often include instant messaging and other similar services.

1.7 Social networking is the use of dedicated websites and applications to interact

with other users, or to find people with similar interests. Popular examples include ‘Facebook’, ‘Twitter’ and ‘LinkedIn’.

1.8 This policy is necessary as many employees enjoy sharing their professional

knowledge and experience with others of similar roles and interests. The Trust encourages these professional online activities and acknowledges that staff can improve their personal skills and experience through relevant interactions with colleagues outside the Trust.

1.9 However, the Trust has a responsibility to ensure the operational effectiveness

of its business, including its public image, reputation and for the protection of its information assets of all kinds. This involves ensuring confidentiality and maintaining security in accordance with NHS information governance policy and good practice.

1.10 As in all their conduct, staff must be mindful of how their behaviour on social

media reflects the values of the Trust:

• Caring and compassionate

o Put ourselves in other people's shoes

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o Listen and offer hope o Focus on recovery o Be approachable o Be sensitive and considerate o Be helpful o Go the extra mile o Respectful o Value the skill and contribution of others o Give respect to all people o Respect and embrace difference o Encourage innovation and be open to new ideas o Work together and value our partners

• Honest and transparent

o Have no secrets o Be open and truthful o Accept what is wrong and strive to put it right o Share information o Be accountable for our actions

2 Purpose 2.1 This policy is provided so that members of staff of the Trust are aware of their

personal responsibilities when engaging in the use of media. 2.2 The purpose of this policy is to provide guidance to Trust staff, volunteers and

Governors on the process which must be followed for handling any media requests. This applies to all media enquiries, regardless of whether the enquiry relates directly to the Trust, an individual’s role within the Trust or any links that staff may have with professional bodies or organisations.

3 Duties, accountabilities and responsibilities 3.1 The Trust is committed along with its staff and staff side partners, to providing

and environment where staff are treated with dignity and respect in all areas of their work and that includes any activities that may be connected or be related to their place of work.

3.2 The Trust views any activity committed by a CNTW employee whilst using a

social networking site that may be viewed as discrimination, harassment, bullying or victimisation towards another employee, patient or carer or family member of a service user of CNTW, as a serious contravention of its commitment to equal opportunities.

3.3 Any perpetrator of such action may be subject to disciplinary action up to and

including dismissal in accordance with the Trust’s CNTW(HR)04 - Disciplinary policy.

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3.4 The Trust also views any activity committed by a CNTW employee whilst using a social networking site, that may bring the Trust in disrepute as a serious contravention of the standards of behaviour expected of all Trust employees.

3.5 Any perpetrator of such action may be subject to disciplinary action up to and

including dismissal in accordance with the Trust’s Disciplinary Policy CNTW(HR)04.

3.6 Chief Executive – has ultimate responsibility for the implementation of this

policy including ensuring that the Trust policies comply with all legal, statutory and good practice requirements.

3.7 Director of Communication and Corporate Affairs – has delegated

responsibility and reports to the Executive Team and Board of Directors on all issues relating to media.

3.8 Executive Directors/Deputy Directors/Group Directors/ Heads of

Service/Managers/Supervisors – are responsible for ensuring adequate dissemination and implementation of this policy amongst staff, including contractors and agency staff. They have a responsibility to ensure employees are informed that inappropriate activities carried out by employees on social networking site that have a negative or detrimental impact on the Trust, colleagues, patients or service users may be viewed as a disciplinary offence. Managers made aware of any such activity should take immediate action and seek the advice of the workforce team at the first opportunity.

3.9 Caldicott Guardian/Senior Information Risk Owner (SIRO) - has a strategic

role which involves representing and championing confidentiality and information sharing requirements and issues at senior management level. In addition, they actively support information sharing and advise on options for lawful and ethical processing of information. As such, the Caldicott Guardian/SIRO will be called upon for advice in relation to engagement with the media – including on social media – and in any circumstances where staff may have contravened this policy.

3.10 Human Resources (HR) – HR staff have a responsibility to ensure that all new

staff are made aware of this policy by ensuring the policy is referenced in the Trusts induction programme.

3.11 All employees of the Trust have a personal responsibility for their own

behaviour and are required for ensuring their conduct is in line with the standards set out in this policy. Staff should:

• Be aware of this policy and comply with it

• Set a positive example by treating others with respect at all times

• Do not make personal or offensive comments

• Be supportive of colleagues who may be subject to inappropriate activities on social networking sites

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3.12 The Communications Department will have responsibility for monitoring the

effectiveness of this policy which will be regularly reviewed. 4 Definitions of Terms Used

• Media – the term ‘media’ or ‘mass media’ refers to means of communication which reach large numbers of people in a short time. Traditional media, introduced before the arrival of the internet, includes television, radio, newspapers and magazines. Today’s media world includes a wide range of online publications. In addition to which most ‘traditional’ media also broadcasting or sharing news online.

• Journalists – are people who write for newspapers, magazines or online publications. They also film/record news and prepare new stories to be broadcast online, on the radio or on television.

• Lead Officer: The Director accountable for the policy

• Author(s): The person nominated by the Lead to prepare the Policy

• Development: A process by which something passes by degrees to a different stage, process of clarification

• Consultation: An exchange of views, time limited period during which the views/advice of others are sought to further inform the Policy content

• Ratify: Formal agreement and acceptance

• Implement: Put into practice/operation

• Embedded: Established

• Review: Reassess 5 The Trusts work with the media 5.1 Effective communications are essential to the success of any organisation and

accordingly, Cumbria, Northumberland, Tyne and Wear NHS Foundation Trust aims to use the media to build good, open relationships with patients, their families, partner organisations, key stakeholders and the wider public.

5.2 The Trust engages with the media on the basis of authority and knowledge so

that information in the public domain is reliable, trustworthy and accurate so that public confidence in the Trust can be maintained and enhanced.

5.3 As an organisation we work closely with the media – proactively and reactively for several reasons:

• To respond to legitimate enquires

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• To publicise the work of the Trust

• To promote the services, we offer

• To provide information to the public

• To support clinical and/ or operational objectives

• To raise awareness of health issues

• To promote general health and wellbeing

5.4 On occasion media outlets request to interview/ film/ speak to staff and/ or patients. This may occur on one of our sites or in the wider community. In such circumstances, it is the Communications Team’s role to liaise with the Journalist to ascertain the nature of the enquiry and coordinate an appropriate response.

5.5 Consent is required in all circumstances where the subject (staff or patient) could reasonably be identifiable. In the case of a member of staff, verbal consent, given to a member of the Communications Team, to appear is sufficient. Where a patient is visually identifiable –i.e. sitting in the background of a wider shot - then consent (recorded or written) must be obtained and recorded on RiO. If a patient is to be interviewed or appear as the focus of a broadcast, then written consent is required. At no point will any patient or member of staff be subjected to undue pressure to take part in any media process with which they are uncomfortable.

5.6 Where a patient or member of staff consents to participate in media engagement, the member of the Communications Team present will offer any advice or guidance which may be required.

5.7 At all times the right of our patients, their families and staff to privacy and dignity is, and will remain, our overriding priority. At all times, in all media engagement, the Trust complies with the Caldicott guidelines, the Ofcom broadcasting code, appropriate editorial guidelines, the General Data Protection Regulation (GDPR) and industry best practice to ensure this objective is met.

6 VIPs visits on Trust Premises 6.1 The Trust may, on occasions, arrange for external persons to visit Trust sites

and meet patients when appropriate. For example, celebrities or VIP visits from local Members of Parliament or national dignitaries.

6.2 When this does occur, all persons are accompanied at all times by a member of the Communications Team who will also make necessary arrangements to ensure that staff are fully briefed about the visit. An appropriate member of the relevant department must also escort the visitor(s).

6.3 A member of the Communications Team will also coordinate all media activity related to the visit.

7 Protocol for Media enquiries 7.1 All Media enquiries must be directed to the Trust’s Communications Team

immediately using any of the contacts below:

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Communications office: 0191 245 6877 Head of Communications: 07500 891 361 Communications Advisors: 07469 036 624/07976 865 153

7.2 A member of the Communications Team can be reached out of hours via switchboard.

7.3 Whilst the majority of Journalists will contact the Trust via the Communications Team, there may be instances where staff are approached directly. For example, Journalists may approach certain staff directly (via phone, social media or email) for their expert comment or opinion. Equally, it is possible that Journalists may ring wards directly during a major incident.

7.4 In these circumstances, staff should advise that all media enquiries must go through the Trust’s Communications Team.

7.5 Similarly, if a Journalist or Camera Operator turns up on site unannounced, staff should contact the Communications Team immediately who will handle the situation. If a member of staff notices someone taking photographs/filming on the site unaccompanied by a member of the Communications Team, they should approach them and ask what they are doing then alert the Communications Team.

7.6 All photographing/filming requests must be agreed with the Communications Team in advance.

7.7 We recognise that some members of staff are highly active within their own professional bodies and may be contacted by the respective Press Offices of their professional bodies, or by Journalists, in relation to their work or any national announcements. In all cases, staff should contact the Trust Communications Team before speaking to the Journalist or agreeing to take part in an interview so the Communications Team can provide appropriate advice.

7.8 All staff should be aware that the Public Interests Disclosure Act 1998 gives legal protection to employees who wish to ‘whistleblow’ any concerns. The Act makes it clear that the process of “whistleblowing “or “speaking up” normally involves raising the issue internally first. Using the media to whistleblow would not be considered appropriate and all staff should raise concerns through the proper channels, as outlined in the Trust’s Raising Concerns Policy CNTW(HR)6 V05.

7.9 Do’s and don’ts

• Don’t ever feel pressured by a journalist to make a comment or give any information

• Do refer journalists immediately to the Communications Team straight away as the media are often working to tight deadlines and will require a swift response

• Don’t ignore anyone who is on a hospital site and has a camera or you think may be a journalist

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• Do call the Communications Team immediately so that appropriate arrangements can be made, and patient/staff confidentiality is protected

• Don’t agree to an interview prior to alerting the Communications Team to any request you’ve had

• Do call the Communications Team straight away if you have been approached by a journalist directly

• Don’t, under any circumstances, disclose confidential information to the media. All enquiries from such sources should be referred to the Communications Team.

• Do proactively contact the Communications Team if you are engaging with the media for a non-professional reason (i.e., charity fundraising, events in your personal life etc.) where you mention or use your professional role or the Trust’s Charity)

8 Private use of social media 8.1 Staff of the Trust may use social media for private purposes during their work

breaks. 8.2 Staff should be aware that the Trust reserves the right to monitor the web,

including social networking sites, for content that it finds inappropriate. 8.3 The Trust also reserves the right to monitor staff usage of social networking

sites in work time. 8.4 When using social media, members of staff are encouraged to state that they

are communicating in a personal capacity. 8.5 This can be done by adding a disclaimer to private online profiles, such as “All

views are my own and do not necessarily reflect those of my employer”. 8.6 Members of staff are ultimately responsible for their own online behaviour.

However, they remain bound by the Trust’s CNTW(HR)04 - Disciplinary policy. 8.7 Social media has blurred the boundaries between a person’s private and

professional lives. Members of staff who use social media in their personal life should therefore be mindful that inappropriate use could damage their own reputation and that of the Trust and could lead to disciplinary action being taken.

8.8 Many members of staff are also obligated by professional codes of conduct

which require appropriate, confidential and responsible behaviour in all communications, private and professional; online or otherwise.

8.9 The following are the social media policies of a number of professional

organisations of which staff may be members. The following list is not exhaustive and should not be taken as such:

• Nursing & Midwifery Council

• General Medical Council

• Health and Care Professions Council

• Royal College of General Practitioners

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• British Medical Association

• Royal College of Nursing

• Royal Pharmaceutical Society

• British Association of Occupational Therapists & College of Occupational Therapists

• British Dietetic Association

• Chartered Society of Physiotherapy

8.10 Staff should refer to the “Think when using social media” guidance appended to this policy (see Appendix 1).

9 Professional use of Media 9.1 Staff are not authorised to use any form of media to communicate on behalf of

the Trust as a whole. Staff may only do so once the appropriate permissions have been put in place via the Communications Team.

9.2 This does not mean that members of staff are prohibited from stating that they

work for the Trust and from making professional statements, only that they cannot imply that their views are the views of the Trust as a whole.

9.3 When a member of staff identifies their association with the Trust – for example,

by stating they work for the Trust and/or discusses their work, they are expected to behave professionally, and in a way that is consistent with the organisation’s values and policies.

9.4 Staff may use social media in work time so long as there is a clear professional

purpose, such as viewing training material on YouTube or taking part in a professional forum on Twitter.

9.5 Staff must not disclose information about the Trust that is or may be sensitive

or confidential, such as information about service users, other staff and stakeholders, other organisations, commercial suppliers and other information about the Trust and its business activities.

9.6 Corporate logos or other visible markings or identifications associated with the

Trust may only be used where prior permission has been obtained from the Communications Team.

9.7 All official social media sites are managed by the Communications Department.

No other teams/staff within the Trust should set up corporate sites without the authorisation of the Communications Department.

9.8 When authorised users are posting to social media accounts, they have a responsibility to ensure that any information they are sharing is from a reputable source.

9.9 Staff should not set up sites that are made to resemble an official site.

http://www.csp.org.uk/publications/social-media-guidance

http://www.csp.org.uk/publications/social-media-guidance

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10 Identification of Stakeholders 10.1 This Policy applies to all Trust employees and following the criteria set out in

CNTW(O)01 – Development and Management of Procedural Documents. This Policy was circulated Trust-wide for a two-week consultation to the standard distribution listed below:

• North Locality Care Group

• North Cumbria

• Central Locality Care Group

• South Locality Care Group

• Corporate Decision Team

• Business Delivery Group

• Safer Care Group

• Communications, Finance, IM&T

• Commissioning and Quality Assurance

• Workforce and Organisational Development

• NTW Solutions

• Local Negotiating Committee

• Medical Directorate

• Staff Side

• Internal Audit

• Health Safety Security and Resilience

11 Training 11.1 New starters will be made aware of the policy through Induction training. The

policy will also be included in the Managers Reference Book and copies will be available via the Trust intranet and policy files kept on the ward.

11.2 A rolling programme of social media training will be conducted across the Trust

to introduce staff to the policy and give them general advice on the safe use of social media.

12 Implementation 12.1 The media policy was implemented in February 2021 and will be reviewed

every three years. 13 Monitoring and Compliance 13.1 Policy compliance will be the reporting of the number of disciplinary cases

stemming from inappropriate activity by employees on social networking or other new media sites.

13.2 The policy will also be part of the Trust’s induction programme and the number

of staff who have completed corporate and local induction will be recorded.

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14 Fair Blame 14.1 In terms of reporting incidences relating to social media use the Trust endorses

the view that, wherever possible, disciplinary action will not be taken against members of staff who report near misses and adverse incidents, although there may be clearly defined occasions where disciplinary action will be taken.

15 Fraud, Bribery and Corruption 15.1 In accordance with the Trust’s Policy, CNTW(O)23 Fraud, bribery and

corruption policy, all suspected cases of fraud and corruption should be reported immediately to the Trust’s Local Counter Fraud Specialist or to the Director of Finance.

16 Equality and diversity assessment 16.1 In conjunction with the Trust’s Equality and Diversity Officer this policy has

undergone an equality and diversity impact assessment which has taken into account all human rights in relation to disability, ethnicity, age and gender. The Trust undertakes to improve the working experience of staff and to ensure everyone is treated in a fair and consistent manner.

17 Associated Documents

• CNTW(O)01 Development and management of procedural documents

• CNTW(O)23 Fraud, bribery and corruption policy

• CNTW(HR)04 Disciplinary policy

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Appendix A

Equality analysis screening toolkit

Names of Individuals involved in Review

Date of Initial Screening

Review Date Service Area / Directorate

Christopher Rowlands February 2021 February 2024 Trust-wide

Policy to be analysed Is this policy new or existing?

CNTW(HR)24 - Social Media Policy – V04 Existing

What are the intended outcomes of this work? Include outline of objectives and function aims

Social networking is the use of interactive web-based sites or social media sites, allowing individuals on-line interactions that mimic some of the interactions between people with similar interests that occur in life. Popular examples include Facebook, Twitter and LinkedIn. This Policy is necessary as many employees enjoy sharing their professional knowledge and experience with others of similar roles and interests. The Trust encourages these professional online activities and acknowledges that staff can improve their personal skills and experience through relevant interactions with colleagues outside the Trust.

Who will be affected? e.g. staff, service users, carers, wider public etc

Staff

Protected characteristics under the Equality Act 2010. The following characteristics have protection under the Act and therefore require further analysis of the potential impact that the policy may have upon them

Disability No impact

Sex No impact

Race No impact

Age No impact

Gender reassignment

(including transgender)

No impact

Sexual orientation. No impact

Religion or belief No impact

Marriage and Civil Partnership

No impact

Pregnancy and maternity

No impact

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Carers No impact

Other identified groups No impact

How have you engaged stakeholders in gathering evidence or testing the evidence available?

Through standard consultation routes

How have you engaged stakeholders in testing the policy or programme proposals?

This is a review of a current policy

For each engagement activity, please state who was involved, how and when they were engaged, and the key outputs:

Policy Review Group – engaged via meetings and email correspondence – key output – revised policy

Summary of analysis

No impact

Now consider and detail below how the proposals impact on elimination of discrimination, harassment and victimisation, advance the equality of opportunity and promote good relations between groups. Where there is evidence, address each protected characteristic

Eliminate discrimination, harassment and victimisation

Not applicable

Advance equality of opportunity Not applicable

Promote good relations between groups Not applicable

What is the overall impact?

Not applicable

Addressing the impact on equalities Not applicable

From the outcome of this Screening, have negative impacts been identified for any protected characteristics as defined by the Equality Act 2010? NO If yes, has a Full Impact Assessment been recommended? If not, why not? Manager’s signature: Chris Rowlands Date: February 2021

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Appendix B Communication and training check list for policies Key questions for the accountable committees designing, reviewing or agreeing a new Trust policy

Is this a new policy with new training requirements or a change to an existing policy?

Existing policy

If it is a change to an existing policy are there changes to the existing model of training delivery? If yes specify below.

No

Are the awareness/training needs required to deliver the changes by law, national or local standards or best practice?

Please give specific evidence that identifies the training need, e.g. National Guidance, CQC, NHSLA etc.

Please identify the risks if training does not occur.

Please specify which staff groups need to undertake this awareness/training. Please be specific. It may well be the case that certain groups will require different levels e.g. staff group A requires awareness and staff group B requires training.

All staff should have an awareness of the policy and understanding of their own responsibilities

Is there a staff group that should be prioritised for this training / awareness?

All staff

Please outline how the training will be delivered. Include who will deliver it and by what method. The following may be useful to consider: Team brief/e bulletin of summary Management cascade Newsletter/leaflets/payslip attachment Focus groups for those concerned Local Induction Training Awareness sessions for those affected by the new policy

A rolling awareness programme will be provided by the Communications Team and will take place on an on-going basis across a number of formats – which includes written Instructions as well as the team answering queries both verbally and in writing as well as updates in the Bulletin and intranet. Trust Induction

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Local demonstrations of techniques/equipment with reference documentation Staff Handbook Summary for easy reference Taught Session E Learning

Please identify a link person who will liaise with the training department to arrange details for the Trust Training Prospectus, Administration needs etc.

Adele Joicey

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Appendix B – continued

Training Needs Analysis

Staff/professional group Type of Training

Duration of Training

Frequency of Training

All staff Rolling awareness

On-going basis

On-going basis

Should any advice be required, please contact: [email protected]

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Appendix C Monitoring Tool Statement The Trust is working towards effective clinical governance and governance systems. To demonstrate effective care delivery and compliance, policy authors are required to include how monitoring of this Policy is linked to auditable standards / key performance indicators will be undertaken using this framework.

CNTW(HR)24 – Social Media Policy - Monitoring Framework

Auditable Standard/Key Performance Indicators

Frequency/Method/ Person responsible

Where results and any associated action plan will be reported to, implemented and monitored; (this will usually be via the relevant governance group)

1. Breaches of this policy will be captured using the Vuelio Media Monitoring Tool

The Communications Team have a contract with Vuelio media monitoring service which can be used to prepare and distribute social media reports.

Corporate Decision Team

The Author(s) of each Policy is required to complete this monitoring template and ensure that these results are taken to the appropriate Quality and Performance Governance Group in line with the frequency set out.