Social Media Policy

1.1 This policy will enable and encourage employees, seconded staff and members of its associated bodies to use social media to enhance their work and raise the profile of our organisation in a positive and appropriate way. It will help protect the interests of the Health Services Safety Investigations Body (HSSIB), its employees, seconded staff and members of its associated bodies, whether they are acting independently or in their capacity as a representative of HSSIB.

1.2 The purpose of this policy is to provide guidance to all HSSIB employees, seconded staff and members of its associated bodies on the use of social media and digital platforms by HSSIB as an organisation and by individuals in both a personal and professional capacity.

1.3 This policy will:

• Encourage employees, seconded staff and members of our associated bodies to positively and appropriately raise the profile of HSSIB and its work through the use of social media.
• Encourage employees, seconded staff and members of our associated bodies to make use of and contribute to HSSIB’s official social media accounts.
• Ensure that social media and digital platforms are used in a strategic way.
• Ensure that internet users can distinguish official HSSIB information from the personal opinion of employees, seconded staff and members of our associated bodies.
• Ensure that HSSIB’s reputation is not brought into disrepute and that it is not exposed to any legal risk.

2.1 This policy applies to members of staff that are directly employed by HSSIB and for whom HSSIB has a legal responsibility.

2.2 For seconded staff, staff covered by a letter of authority/honorary contract, members of our associated bodies or those on work experience, the organisational policies are also applicable whilst undertaking duties on behalf of the organisation.

This document is not a social media strategy, or guidance on how to use individual social media tools and platforms, and each individual or business area should assess the value of using these tools in an official capacity and follow this policy if they decide to do so.

3.1 ‘Social media’ or ‘social networking’ are the terms commonly used to describe websites and online tools which allow users to interact with each other in some way by sharing information, opinions, knowledge and interests. For the purposes of this policy, social media refers to social media networking platforms including, but not limited to, X (formerly known as Twitter), Facebook, Facebook Messenger, YouTube, LinkedIn, Instagram, Pinterest, Google+, Snapchat, TikTok, WhatsApp, Bluesky and Reddit. It also covers blogs, discussion forums, interactive news sites and online activity in general, as well as digital platforms used to send email campaigns and online survey tools e.g., SurveyMonkey and SmartSurvey.

4.1 The Communications Team has overall responsibility for HSSIB’s social media accounts.

4.2 The Digital Communications Manager is responsible for day-to-day management.

4.3 Individual staff use: our staff are our best ambassadors. Many already use social media, both in a personal and professional capacity. We recognise that there is an increasingly blurred line between personal and professional use of social media. This is to the extent that it may no longer be possible or desirable to make that distinction. For example, users are likely to maintain just one Bluesky account, which is used to post a mix of business related and personal content. HSSIB encourages this activity.

4.4 The Communications Team is available to provide guidance and training to empower staff to interact online in a way that is consistent with our values and professional codes of conduct. Even if you do not use your social media accounts in a professional capacity, content posted through personal accounts that are public and can be seen may breach HSSIB policy if they bring the organisation into disrepute. This includes situations when you could be identified as an HSSIB employee, secondee or member of our associated bodies whilst using social media or occasions when you may be commenting on HSSIB related matters in a public forum.

4.5 Please be aware that even if you believe you are using social media sites with enhanced privacy settings applied, this does not exempt you from the guidelines in this policy.

4.6 If you are concerned about the online conduct of any other employee, secondee, or member of an associated body, you should speak to an appropriate manager in line with relevant HSSIB policies.

4.7 If you are asked to blog or participate in a social network for commercial or personal gain, then this could constitute a conflict of interest. You should refrain from entering any online social networking activity for commercial gain. If someone from the media contacts you about a post you have made, you must talk to the Communications Team (comms@hssib.org.uk).

4.8 More generally, staff should use their own discretion and common sense when engaging in personal social media. The following gives some general guidance and best practice which you should abide by at all times:

Be honest about who you are.

If the conversation relates to the NHS, patient safety, safety investigations, or HSSIB, you should identify yourself as an employee. For example, if you mainly use Bluesky or X in a professional capacity you are encouraged to state in your biography that you work for HSSIB and, in the case of Bluesky, include our handle (@hssib.bsky.social).

Clarify that your opinions are your own.

Make it clear that you are speaking for yourself and not on behalf of HSSIB. Include a sentence in your profile or biography that says views are your own and not those of your employer (whilst a disclaimer like this does not have any legal standing, it helps users distinguish official HSSIB information from the personal opinion of employees). This includes content published to any website outside of HSSIB that could be perceived to have a connection to the work you do, or subjects associated with HSSIB. You must not use HSSIB’s logos on personal webpages or social media accounts. You must not include ‘Health Services Safety Investigations Body’, ‘HSSIB’, or any other variations on our name in your account names or handles.

Be respectful.

The same principles and guidelines that apply to staff activities in general also apply to social media. Show respect to your colleagues and external users. If you would not say something in a meeting or email, do not say it online. Do not use social media in any way to attack or abuse colleagues. Do not use personal insults, obscenities, or engage in any conduct that would not be acceptable in the workplace. You should also show proper consideration for others' privacy and for topics that may be considered objectionable or inflammatory, such as politics and religion.

Use good judgement in what you share

Only ever share public information. Respect copyright, fair use, data protection, defamation, libel and financial disclosure laws. Do not reveal confidential personal information about patients, colleagues, or HSSIB staff members. Never post any information that can be used either alone or with other information that could be used to reveal the identity of another. Do not reveal sensitive commercial information about HSSIB or its stakeholders. Our confidentiality and other associated governance policies apply to information shared using social media.

Be aware that what you say is permanent

Search engines and other technologies make it virtually impossible to take something back once it has been published.

Raising concerns and whistleblowing

Do not use social media to ‘whistleblow’. Concerns should only be raised through the proper HSSIB channels.

Other concerns

If you encounter any of the following situations, you should not engage (or politely disengage) and seek advice from the Communications Team (comms@hssib.org.uk) and your line manager:

• Interactions that are or could become antagonistic.
• Content that impacts you negatively.

Staff are reminded that the Health and Care Act 2022 (the "HCA 2022") establishes a prohibition on the disclosure of "protected material" which is held as part of an investigation. Protected materials are defined under Section 122 of the HCA 2022 as any information, document, equipment or other item which is held by HSSIB for the purpose of its investigation function and which relate to an incident occurring in England during the provision of health services which has, or may have implications for the safety of patients. It is an offence for a person to disclose protected material except when limited exemptions apply. For further information on when protected material can be disclosed, please see contact ig@hssib.org.uk.

You should not disclose protected material unless you have the appropriate authority to make a disclosure. Where you consider it necessary to disclose protected materials, or you need further guidance on protected materials or the relevant exemptions, you should contact the Board, Governance and Records Manager on ig@hssib.org.uk who will be able to provide further guidance.

5.1 A list of the social media and other digital platforms on which HSSIB maintains corporate accounts can be found in appendix one.

5.2 Whilst we encourage individual members of staff to use their personal social media accounts to reflect positively on the work of HSSIB, it is important that the organisation maintains a coherent online presence through the strategic use of these official social media accounts and digital platforms. Therefore, without having gained approval from the Communications Team and senior leadership team, employees, secondees and members of associated bodies must not engage in setting up Bluesky accounts, X accounts, Facebook pages, YouTube channels, blogs, online survey accounts or a presence on any other social media website or digital platform that seeks to represent the official views of HSSIB or any of its teams or workstreams.

5.3 The official HSSIB social media accounts and digital platforms are managed by the Communications Team. Teams across HSSIB are encouraged to contribute content to these official accounts by contacting the Digital Communications Manager.

5.4 Any team seeking to set up their own social media presence should prepare a business case outlining how this activity will benefit HSSIB and the benefits to be realised, compared to the costs in time and resources of doing so. Given the time and resource involved in effectively building and managing a presence on social media, there must be a clearly evidenced demand from an audience for engagement activity using a particular channel, rather than engagement using existing official social media accounts or other channels of communication.

6.1 Business Impact Assessment
As part of the development of this policy, its impact has been assessed and no detrimental issues were identified.

6.2 Equality Impact Assessment
As part of the development of this policy, its impact on equality has been analysed and no negative impact has been identified.

6.3 Training
Staff will receive instruction and direction regarding the policy from a number of sources:

• Policy and supporting guidelines and protocols.
• Advice and guidance from the Communications Team.
• Articles and information on the internet.

7.1 Performance against key indicators will be regularly monitored, reviewed and used to inform the development of future policies and guidelines.

7.2 Due to the rapidly evolving nature of social media and digital platforms this policy will be reviewed every two years, and in accordance with the following on an as and when required basis:
• legislative changes
• good practice guidance
• case law
• significant incidents reported
• new vulnerabilities
• changes to organisational infrastructure.

7.3 HSSIB policies apply to all forms of communication whether verbal, printed or online. Staff should remember that they are ultimately responsible for what they publish online. If you are considering publishing something that makes you even slightly uncomfortable, review the policy above and ask yourself why that is. If you’re in doubt or in need of further guidance, please contact the Communications Team to discuss. Non-compliance with policies and guidance may lead to disciplinary action in accordance with the HSSIB disciplinary procedure.

7.4 The Communications Team is available to provide help and advice. They should be consulted in the early stages of the planning process around any communications activity. Please contact comms@hssib.org.uk.