UW Medicine Compliance
Social Media Policy and Guidelines – COMP.303
This document includes UW Medicine’s policy limiting the use of social media in hospital and clinic spaces, institutional policies that apply to the use of social media and best practice guidelines for UW Medicine faculty, staff, trainees, students, volunteers and others who perform work for UW Medicine (hereafter referred to as workforce members). Social media includes text, images, audio and video communicated via such tools as:
- Blogs and micro-blogs,
- Social networks;
- Professional networking sites
- Profession-based social networks;
- Video sharing;
- Audio sharing;
- Photo sharing;
- Social bookmarking;
- Public comment sections on webpages (such as those for online news sites);
- User created web pages; and
- Any other internet-based social media application similar in purpose or function to those applications described above.
To ensure your awareness of the most comprehensive and current list of social networking platforms and sites, visit the following website: https://en.wikipedia.org/wiki/List_of_social_networking_websites.
Please consult your entity-specific social media policies in addition to this document.
Social networking sites can be an effective way to keep in touch with colleagues; in medical education, wikis and discussion boards are already heavily utilized. Social media such as Facebook, LinkedIn, Twitter, Google+ and Instagram have grown in popularity and application, allowing users to post content and share with virtually anyone. Organizations, including healthcare institutions, are rapidly integrating the use of social media into their education, outreach and marketing strategies.
While this creates new opportunities for communication and collaboration, it also creates vulnerabilities for individuals and institutions, especially those involved in the healthcare environment. Depending on our privacy settings, anyone with access to the internet can see our profiles, photos and posted opinions and can share them anywhere. The potential impact on one’s image and the institution’s image is an important consideration.
Social networking is a platform to build social networks or social relations among people who share similar interests, activities, backgrounds or real-life connections. A social network service consists of a representation of each user (often a profile), his or her social links, and a variety of additional services. Social network sites are web-based services that allow individuals to create a public profile, create a list of users with whom to share connections, and view and cross the connections within the system. Most social network services are web-based and provide means for users to interact over the Internet, such as e-mail and instant messaging. Social network sites are varied and they incorporate new information and communication tools such as mobile connectivity, photo/video/sharing and blogging. (Wikipedia, Social networking service, https://en.wikipedia.org/wiki/Social_networking_service (as of September 22, 2015, 19:00 GMT)).
Use of social media is prohibited while performing direct patient care activities or in unit work areas, unless social media use in these areas has been previously approved by a supervisor. Workforce members should limit their use of social media in hospital or clinic space to rest or meal breaks, unless social media use for business purposes has been previously approved by a supervisor.
1. Think twice before posting. Privacy does not exist in the world of social media. Consider what could happen if a post becomes widely known and how that may reflect on both you and UW Medicine. Search engines can turn up posts years after they are created, and comments can be forwarded or copied. If you would not say it at a conference or to a member of the media, consider whether you should post it online. If you are unsure about posting something or responding to a comment, seek advice from your supervisor, residency or academic advisor or the department head.
2. Anonymity is a myth. Write everything as if you are signing it with your name.
3. Remember your audience. A presence in the social media world is or easily can be made available to the public at large. This includes prospective and current students, current employers and colleagues, patients and their families and peers. Consider this before publishing to ensure the post will not alienate, harm or provoke any of these groups.
4. Strive for accuracy. Get the facts straight before posting them on social media. Review content for grammatical and spelling errors. This is especially important if posting on behalf of UW or UW Medicine in any capacity.
5. Familiarize yourself with and use conservative privacy settings regardless of the content on your profile. Practice restraint when disclosing personal information on social networking sites; your audience is everyone.
6. Consider your professional image. As a rule, post online only content that you would be comfortable having your chair or supervisor see. Employers often search social networking sites during the hiring process. Always consider the professional image you wish to present to your employer, coworkers, patients and their families. Even seemingly innocuous images and comments can diminish the respect and trust that others have for you.
7. Do not “friend” patients on social networking sites.
8. Managers are discouraged from engaging in social media interactions with their subordinates, even if a subordinate initiates contact. UW Medicine discourages such interactions because of the potential for misunderstandings and undesirable effects on supervisory relationships.
9. Ask permission before posting medically-related content on social media sites. If you are faculty or staff, ask permission from someone with appropriate authority in your chain of command. If you are a resident or student, ask permission from someone with appropriate authority in your program.
10. If in doubt, do not post!
11. Use disclaimer language. If you acknowledge your UW Medicine affiliation or you may be otherwise known or presumed to be affiliated with UW Medicine, include disclaimers in your online communications that indicate you are not speaking officially on behalf of the organization.
a. “The postings on this site are my own and do not represent the positions, strategies or opinions of my employer (or the University of Washington and UW Medicine)”; or
b. “This is a personal website, produced in my own time and solely reflecting my personal opinions. Statements on this site do not represent the views or policies of my employer, past or present, or any other organization with which I may be affiliated. All content is copyrighted.”
12. Even disclaimers are not failsafe. Standard disclaimer language may not by itself exempt UW Medicine managers and executives from a special responsibility when blogging. By virtue of their position, managers and executives must consider whether personal thoughts they publish may be misunderstood as expressing UW Medicine positions. Managers should assume that their team may read the blog.
13. Do not engage in cyberbullying. Do not harass, libel, slander or embarrass anyone. Do not post any material that is obscene, defamatory, profane, libelous, threatening, harassing, abusive, hateful or embarrassing to another person or entity. Individuals may be held personally liable for defamatory, proprietary or libelous commentary.
14. Disclose your relationship. If you make comments that could reasonably be construed as an endorsement of UW Medicine’s services, disclose your relationship with UW Medicine.
1. Confidential, proprietary and trade-secret information about UW Medicine or its affiliates, students, employees or alumni may not be posted.
2. Patient privacy must be maintained in all communications. Do not disclose information that may be used to identify patients or their health condition, without the express and written permission of the patient, and remember that even de-identified information may be recognized by patients, their families or their employers. Relevant UW Medicine Compliance policies include COMP.103 Use and Disclosure of Protected Health Information.
3. Intellectual property rights must be preserved. If you have any questions regarding UW Medicine and UW’s intellectual property rights, please contact the appropriate department prior to any use: http://depts.washington.edu/uwcopy/UW_Policies/UW_Contacts/.
a. For comprehensive guidance on relevant laws and UW Medicine policies, consult the UW Copyright Connection at http://depts.washington.edu/uwcopy/Copyright_Connection/.
b. UW Patent, Invention and Copyright Policy: http://www.washington.edu/admin/rules/policies/PO/EO36.html
c. UW Digital Millennium Copyright Act: http://www.washington.edu/itconnect/work/appropriate-use/uw-dmca-digital-millennium-copyright-act-information/.
d. UW Trademark and Licensing Policies: http://depts.washington.edu/uwlogos/uw-resources/policies-procedures.
4. Respect institutional time and property. The use of institutional computers, internet access, networks and time on the job is subject to a number of specific rules and policies, including but not limited to the following:
a. UW workforce members are subject to state law and UW policies that prohibit the use of computers and networks for most personal use except under certain circumstances. State resources may not be used to: support, promote, or solicit for an outside organization or group unless otherwise provided by law and University policy; assist an election campaign, promote or oppose a ballot proposition or initiative, or lobby the state legislature; advertise or sell for commercial purposes; conduct an outside business or private employment or other activities for private financial gain. Supervisors are responsible for: monitoring the use of state resources; determining whether frequency or volume of use complies with the law; counseling workforce members as needed; and revoking access privileges, if necessary.
b. Student use of computers and networks is subject to UW policies, including, but not limited to the following:
i. Using Your Computer in Residence Halls: https://itconnect.uw.edu/work/appropriate-use/#students
ii. Chapter 478-120 WAC: UW Student Conduct Code: http://apps.leg.wa.gov/WAC/default.aspx?cite=478
5. In general, do not use social media sites for personal, non-work related purposes when you are supposed to be doing your job. Be aware there may be more limitations or specific policies governing the use of social media depending on where you work. For example, use of social media in hospital and clinic spaces is restricted (see Policy Statement). UW Medicine entities or departments may also set more restrictive or specific policies regarding access to social media sites. When in doubt, check with your supervisor.
6. Unless you are serving as an approved, official spokesperson for UW Medicine, online communications are your personal opinions and do not reflect the opinion of UW Medicine or its affiliated entities. Each workforce member is personally responsible for his/her posts (written, audio, video or otherwise). (See Guidelines, 11. Use Disclaimer Language)
7. There should be no expectation of privacy when using a UW Medicine and or UW-based account to visit internet websites. Email communications and internet use may be subject to disclosure under the Public Records Act or for audit purposes.
8. Adhere to the rules that apply to all other aspects of your responsibilities as a UW Medicine workforce member, including professionalism, integrity, confidentiality and security. Relevant UW and UW Medicine policies include, but are not limited to, the following:
a. UW Medicine Policy on Professional Conduct: http://uwmedicine.washington.edu/Global/policies/Pages/Professional-Conduct.aspx
b. Entity-specific Codes of Conduct: http://depts.washington.edu/comply/resources/
c. UW Medicine Privacy Policies: http://depts.washington.edu/comply/patient_privacy/
d. UW Medicine Patient Information Security Policies: http://depts.washington.edu/comply/comp_107
f. The UW Access and Use Agreement: http://uwnetid.washington.edu/agree/
g. UW Information Security policies: http://passcouncil.washington.edu/psg/
h. UW Data Management Committee Policies: https://www.washington.edu/uwit/divisions/im/dmc/dmc-policies/
i. UW Guidelines for Electronic Discovery: http://www.washington.edu/admin/ago/ediscovery.pdf
- The American Medical Association Opinion 9.124 (2011) Professionalism in the Use of Social Media
- Department of Health Medical Quality Assurance Commission, Professionalism and Electronic Media