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2012

Social Networking Policy


A TYPICAL POLICY FOR A SWEDISH GOVERNMENTAL INSTITUTION IN THE SOCIAL NETWORKING SITES

February, 2012

Electronic copy available at: http://ssrn.com/abstract=2128064

Social Networking Policy

CONTENTS
Section I: The Introduction 1. 2. The goal of using Social Media DeThe Ministryitions 2 2 2 2 2 3 3 3 3 3 4 4 4 4 5 5 5 5 5 5 5 6

Section II: General references of using social media 1. 2. 3. 4. Social Media Channels of the Ministry of The Ministryance Management of the Social Media Channel IT security and technical matters Public Access and Accessibility

Section III: Employees Guidelines 1. 2. Personal use of Social Media by the employees Positive participation of the employees

Section IV: Substantial Obligations 1. 2. 3. 4. 5. 6. 7. Neutrality and interacting with audience Maintaining the public record Privacy and Outsourcing Intellectual property Secrecy of Information Contractual Issue Public procurement

Section V: The liability The Liability of publishing and the fair competition REFERENCES

Electronic copy available at: http://ssrn.com/abstract=2128064

Social Networking Policy

A TYPICAL POLICY FOR A SWEDISH GOVERNMENTAL INSTITUTION IN THE SOCIAL NETWORKING SITES
SECTION I: THE INTRODUCTION
The Ministry of --- is involved in several activities that the public should know about. It is important that this information is provided to the public in the easiest, fastest and cost effective way. Social media is the most efficient way in which this information can be provided to a great number of audiences given the fact that there are large numbers of people using social media. Therefore, social media will be a way of getting peoples participation. However, without a clear policy there is a risk of misleading participants, and harm could be caused to the ministrys reputation.

1. THE GOAL OF USING SOCIAL MEDIA


The goal of using social media by THE MINISTRY is to create transparency, participation and efficiency between the citizens and the ministry. The Ministry is a forward-thinking authority that actively embraces social media. As a relatively new communications medium, this can offer many benefits to the public authority, citizens, employees and other stakeholders.

2. DETHE MINISTRYITIONS
Social media is a collection of online platforms and tools that people use to share content, profiles, opinions, insights, experiences, perspectives, facilitating conversations and interactions online between groups of people. Social Media is the platform/tools. Social Networking is the act of connecting on social media platforms.

SECTION II: GENERAL REFERENCES OF USING SOCIAL MEDIA


Social media networks change fundamentally the way of communication. These changes affect both the professional and private area. Therefore it is important to make oneself familiar with these new channels of communication. However it is also important to be conscious and careful while using social media.

1. SOCIAL MEDIA CHANNELS OF THE MINISTRY OF THE MINISTRYANCE


THE MINISTRY shall use the micro blogging-system (e.g. Tweeter) for the main purpose of wide spreading the information to the target groups in a short, fast and effective way. THE MINISTRY shall use the micro bloggingsystem as a complementary channel in addition to its website. It guarantees a proper content of the ministrys website on the social network page.

Social Networking Policy

2. MANAGEMENT OF THE SOCIAL MEDIA CHANNEL


The ministry shall identify a well trained staff to manage its social networking site. That includes appointing a number of employees responsible for updating the information, monitoring the feeds and comments posted on the site which also includes reacting in a proper and sensitive way to the users. The Ministry should estimate the driven cost of running the social media sites which includes the cost of maintenance, monitoring of official documents and the cost of the administrative and technical staff.

3. IT SECURITY AND TECHNICAL MATTERS


The ministry should maintain a secure and safe method of accessing the Ministry profile by identifying the people who are authorized to access the account and keeping the log in information like the password away from any unauthorized use. The Ministry should use the functionalities available on the social media to prevent any expected harm like avoiding defamatory comments. The Ministry should adjust the visualization of the institute page to ensure that it will be in line with the ministrys cooperate design.

4. PUBLIC ACCESS AND ACCESSIBILITY


The Ministry has to ensure a good level of accessibility by the users to the information and facilities included in its account without any discrimination.

SECTION III: EMPLOYEES GUIDELINES


The employees of THE MINISTRY are expected to fulfil the similar standards of the professional ethics applied in the offline world and apply it in their online conduct and behaviour.

1. PERSONAL USE OF SOCIAL MEDIA BY THE EMPLOYEES


Using the social media for private purposes is not allowed for the employees during the working hours. The employees should be aware of the nature of the information they personally publish on social media and should observe the reputation of the Ministry in addition to its intellectual property. Employees should critically review the content before it is publish and should respect the privacy of the other employees. The employee should make it clear that he or she is acting personally on his private account and not on behalf of THE MINISTRY.

Social Networking Policy

The employee should be aware of creating and posting of any content that could be linked to the Ministry and could harm the reputation of the ministry.

2. POSITIVE PARTICIPATIO N OF THE EMPLOYEES


The Ministry shall encourage the employee to participate in the institution page e.g. by writing articles or studies. The Ministry shall encourage the employees to use social network as a fast and cheap communication for the work purposes with regard to the security measures in particular cases. The Ministry shall encourage the employees to learn this new tool of communication and teach each other. For this purpose the Ministry has the obligation to offer off line-trainings.

SECTION IV: SUBSTANTIAL OBLIGATIONS


The Ministry of The Ministry has the assignment to guarantee high standards of processing data to and from the user. For that purpose several technical and substantial obligations are mandatory.

1. NEUTRALITY AND INTERACTING WITH AUDIENCE


The Ministry shall maintain the main principles of human rights. This duty embraces five aspects: Not to allow any surveillance by the government over the users through its page. Not to allow the page to be an open space to the hate and the harassment speech. Deal with all people equally and neutral with Non-alignment to the specific party or group of people. No censorship for the user comments and views, apart from comments that violate the law or harm the reputation of the ministry.

2. MAINTAINING THE PUBLIC RECORD


The Ministry has three obligations in this meaning. First, to keep a copy of the formal information published on social media in case this information is required by the public according to the legal requirements of the free access to the public information by the Swedish Public Access to Information and Secrecy Act 2009 and maintaining the public record according to the Swedish Public Record Act 1999. It is important also to determine which information it could be regarded as public information e.g. the login cash, the instance messages, etc. Second, delete the information which is no longer needed according to the Swedish Archive Act 1990.

Social Networking Policy

The Ministry has to consider the information (e.g. comments, feedbacks, idea s, views, etc) received from the users as part of the public record.

3. PRIVACY AND OUTSOURCING


The Ministry shall take care of the users privacy according to the international and national laws by ensuring that no information published or comments inserted in its profile that could infringe its users privacy and shall notice remove such content immediately. The Ministry shall also take under account that the data controller might be located outside Sweden. In this regard there should be an inspection made so that the processing of the information complies with the Swedish Personal Data Act 1998.

4. INTELLECTUAL PROPERTY
The ministry has to keep its logo and name unique on social media sites to maintain the reputation of the institution. The employees also have to be aware of this issue while using social media.

5. SECRECY OF INFORMATION
The Ministry should observe the nature of the information published on social media and twice check if this publication is complying with The Swedish Public Access to Information and Secrecy Act 2009.

6. CONTRACTUAL ISSUE
The Ministry has the duty to read and analyse the terms and the conditions of use before signing up an account on social media to check if it is complying with the applicable laws regarding users privacy protectio n and try opening any possible negotiation with the social media operators to adjust this terms and conditions in the benefits of the Ministry and the page users.

7. PUBLIC PROCUREMENT
Even though initiating social media is mainly free, The Ministry has to follow the rules of purchasing services in accordance with the Swedish Public Procurement Act 2011.

SECTION V: THE LIABILITY


In the course of running an online activity like social networking, the Ministry could face multi kinds of legal responsibilities and liabilities. First and foremost the liability generated from publishing the public information.

THE LIABILITY OF PUBLISHING AND THE FAIR COMPETITION


The Ministry has to determine who is responsible for the publication and updating.

Social Networking Policy

The Ministry shall take the responsibility to ensure reliable publishing of information on its social media page and that includes publishing up-to-date and correct information. Special consideration should be given to the fair competition matter. That is by observing the benefits of other local and international media means and by not manipulate the publication of all the news and events of the ministry by its social media site. The responsibility for the publication required also providing contact information in case of any complaints e.g. wrong or demeaning information against a user. The Ministry has to put sanctions for any inappropriate behaviour.

REFERENCES
1. 2. www.http://heidicohen.com/social-media-deThe Ministryition , Accessed January 8th 2012 www.http://klauseck.posterous.com/mehr-als-100-social-media-policy-beispiele,Accessed January 8th 2012 Henrik Nilsson, (2012). Social media and the public sector (PowerPoint Slides) Pages 1, 2 and 3 of the slides for the purpose of using social media, privacy obligations, record keeping, and contractual issues. Retrieved from lecture notes posted on: www.https://server.pingpong.net/courseId/50209/courseDocsAndFiles.do?nodeTreeToggleFolder=27346 822 Christine Kirchberger, Pam Storr, (2012). Social networks and lawyers (PowerPoint Slides), Pages 2 and 3 of the slides in regards to privacy, liability for content, data protection and intellectual property . Retrieved from lecture notes posted on: www.https://server.pingpong.net/courseId/50209/courseDocsAndFiles.do?nodeTreeToggleFolder=27346 822

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