Agenda Item: 7
Paper No: CM/01/13/06
MEETING:
PUBLIC BOARD MEETING
DATE:
7 FEBRUARY 2013
TITLE OF PAPER: CQC Combined social media/twitter policy
SUMMARY:
The paper is presented to Board for approval. The policy – as it applies to staff - has been
signed off by the Trade Unions, staff forum and has been subject to a diversity and
equalities impact assessment. A version covering Board members previously was signed
off by the Board. This version is intended to cover Board members and all CQC staff
equally.
RECOMMENDED ACTION:
For the Board to note and approve this policy so that it can form part of the suite of policies
that staff should note and adhere to.
Executive Decision/
Board for
information
Executive and Board
decision
Executive and Board
shared decision
Executive and Board
discussion/Board
decision
The Executive Team has
made a decision and the
Board has been informed
The Board has been
consulted in order for the
Executive Team to make
a decision
This is a shared decision
between the Executive
Team and Board
This is for when it is clear
that it is a specific Board
decision (under statutory
and legal requirements)
ie. signing off the annual
accounts
* Check box as required
LEAD DIRECTOR:
Jill Finney
AUTHOR:
James Hedges
DIRECTORATE
DATE:
Strategic Marketing and Communications
14/01/13
SUPPORTING
PAPERS:
Annex A – Social Media Policy
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Paper No: CM/01/13/06
GOVERNANCE
AUDIT TRAIL:
LINK TO STRATEGIC
OBJECTIVES AND
BUSINESS PLAN
The paper policy has been approved by the Chief
Executive and Executive Team.
Such a policy supports high quality communication, the
promotion of CQC discussion of polices and good
governance.
IMPLICATIONS FOR NCSC
None specifically
FINANCIAL IMPACT:
None.
RISK IMPACT:
Lack of such a policy and guidance risk is that a CQC
staff member brings the organisation into disrepute on
social media: having a policy and guidance will help in
taking appropriate action should that occur.
The policy is supportive of staff of use of social media: it
is important that staff are permitted to use these media
but in a manner that does not harm CQC.
No
Healthwatch England staff are on CQC terms and
conditions so this will apply equally to them. The
Healthwatch England Committee will be invited to
consider whether and how it should apply to Committee
members.
REPUTATION IMPACT:
LEGAL IMPLICATIONS:
HEALTHWATCH IMPACT:
EQUALITY IMPACT
ASSESSMENT:
Conducted
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1.
Background
1.1 With the more widespread use of social media, there is a need for the Commission to
make sure that it has in place a suitable making clear for staff and non-executive s
what constitutes appropriate use.
2.
Executive Summary
2.1 This policy is intended to support the use of social media and to assist staff by
making clear their responsibilities when they identity themselves as CQC staff or nonexecutives online. Increasingly organisations have policies such as these. Given the
pace of change in technology and associated culture and behaviours it is suggested
that this policy be reviewed actively at least annually and brought back to the Board if
any substantial changes are proposed.
3.
Conclusion & next steps
3.1 The Board is recommended to approve the policy : once approved it will be brought
to the attention of all staff.
Name:
Title:
Date
James Hedges
Media Office
14/01/13
Annex A
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Social Media Participation Policy
Policy Statement
Introduction
CQC recognises that there are many benefits from using social media, including the
opportunity to listen and engage actively with segments of the public not easily reached by
other media, to increase public awareness about CQC’s activities and services, and to
promote transparency, openness and accountability.
However, there are also risks, for example to reputation of an organisation, from
unguarded statements. These risks need to be managed. CQC does not wish to restrict
the ability of any Board Member or member of staff to use social media. The policy
attached is intended to assist anyone associated with CQC in their use of social media.
Principles
This policy sets out the principles which CQC Commissioners and members of staff are
expected to follow when using social media.
The internet is a fast moving technology which enables users to share opinions and
information, promote discussions and build relationships. Social media is a legitimate and
valuable media channel, which is more dynamic and interactive than traditional media.
While it is impossible to cover every eventuality, the following principles about the use of
social media apply:

All of CQC’s engagement with the public, the media and any organisation will be
based on the core principles of integrity, competence and confidentiality

Anyone associated with CQC must act in a manner which upholds the CQC’s
values and does not bring the CQC into disrepute.

Care must always be taken over any comments, views or opinions that are, or
appear to be, made by or on behalf of CQC, about CQC or its partners (for example
the Department of Health, Healthwatch England, or other regulators), or those it
regulates.

Board Members and employees must not be, or appear to be, improperly influenced
by any commercial, political or personal interests. They must always declare any
relevant interests.

Confidentiality must be respected at all times. Board Members and employees must
not reveal personal information which is confidential or refer to internal CQC policy
discussions, or private dialogue between CQC and other organisations, unless they
have received permission to do so.

Derogatory or offensive comments about CQC, CQC’s partners or the providers
regulated by CQC
Scope
The attached guidance applies to Board and Committee Members and all employees of
CQC including agency staff and interims.
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Whilst this policy applies to anyone involved with CQC equally, Board Members and senior
staff, in particular the senior leadership team must take special care because their
comments are most likely to be taken and quoted as official CQC policy or views.
This policy should be read in conjunction with CQC’s policy regarding engaging with the
media.
This policy supersedes all previous policies and practices in CQC or its predecessor
organisations unless the practice is explicitly stated in an employee’s contractual terms
and conditions.
Role of CQC Media Team
CQC has its own Twitter and Face book accounts with a number of followers. These are
officially managed by the CQC Media Team. Board Members and staff will, therefore,
normally not engage in social media communication officially on behalf of CQC. If they
wish to do so, they should discuss with the CQC Media Team.
Use of social media by Board Members
The Board provides leadership and direction to CQC. The Members of the Board set an
example to the organisation by demonstrating the highest standards of openness, integrity,
respect and probity in their conduct, including in their engagement with the public through
social media.
Board Members using social media are likely to be identified as a CQC Board Member
when they comment as individuals on matters relating to CQC as someone with special
insight, knowledge and experience because of their association with CQC and the Board.
When commenting “professionally”, Board Members should
 be aware that, because of their seniority, comments by Board Members may be
misconstrued as official CQC policy. Board Members should make clear that they
are not commenting
 on behalf of the organisation but are giving their own views, adding a disclaimer
where appropriate
 support CQC’s values by being accurate, fair, thorough and transparent in what
they say, encouraging constructive criticism but not in any way being defamatory or
abusive or bringing the organisation into disrepute
 demonstrate the same standards of behaviour online as expected elsewhere eg by
show courtesy and respect for other people’s opinions, avoiding conflicts of interest,
promoting equality and diversity
 not be party political: Board Members are prohibited from using their position as
Board Members in a party-political context
 deal appropriately with information, and not disclose information into the public
domain which is not already there. The CQC Board is responsible for overseeing
the organisation’s compliance with information security and information governance
policies.
 take account of the rules on whistle-blowing which require that Board Members
report any concerns to the Chair of the Audit and Risk Assurance Committee or in
the event that the ARAC Chair is inappropriate because of personal involvement,
with the Chair of the Board or the Chief Executive
 be aware that even information or comments which are meant to be personal can
be circulated widely and cause unwitting offence or upset
 be aware of the legal considerations in relation to the use of social media, including
copyright (eg of images), confidentiality and privacy issues, defamation or libellous
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content. Board Members can be held personally liable for any commentary deemed
to be offensive, discriminatory or objectionable in some way.
A Board Member who is concerned about any comments in a blog, website, on Twitter or
Face book should discuss their concerns with the CQC Chair.
If a member of the Board uses social media in a personal capacity eg discussing likes and
dislikes unconnected with their role as a Board Member, they should not identify
themselves as a member of the Board.
Breaches of the protocol will be investigated and may be deemed to be a breach of the
Members’ Code of Conduct.
Use of social media by members of staff
When CQC staff are using social media platforms as part of CQC’s work, and if they can
be identified as CQC employees, they must:





seek prior approval from line managers when posting views, or altering on-line
content on the internet
not engage in activities on the internet which might bring the CQC into disrepute;
act in a transparent manner if altering online sources of information;
not use the internet in any way to comment adversely, attack, or abuse
colleagues;
not post derogatory or offensive comments about CQC, CQC’s partners or the
providers regulated by CQC.
Being ‘identified as a CQC employee’ includes at its most obvious, for example displaying
a CQC.org.uk email address of joining a CQC network (on Face book or LinkedIn)
Confidentiality
Through the open nature of social networking, it is also possible for third parties to collate
vast amounts of information therefore care must be taken about the information disclosed
on social networking sites. The CQC information security and information governance
policies continue to apply at all times.
Employees must not reveal or refer to what are intended to be internal CQC policy
discussions, or private dialogue between CQC and other organisations, unless they have
received line management permission to do so.
Staff must also show consideration towards other members of staff when using social
networking sites. Social Networking sites allow photographs, videos and comments to be
shared with thousands of other users. However, it may not be appropriate to share work
related information in this way.
For example, there is an expectation that photographs taken at a private CQC event (a
private Board meeting, or internal away-day for example) will not appear publicly on the
internet. Staff should be considerate to their colleagues in such circumstances and must
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not post information about a colleague unless they have obtained their permission to do
so.
Under no circumstances should offensive comments be made about CQC colleagues on
the internet. This may amount to cyber-bullying. Staff are reminded that the CQC has a
zero tolerance policy on bullying and harassment and this may be deemed a disciplinary
offence.
Open Access Online Encyclopaedias
In the course of CQC work, staff may find errors in online encyclopaedias. If staff members
edit online encyclopaedias at work, the source of the correction will be recorded as CQC
IP address. The intervention may therefore look as if it comes from CQC itself. Staff should
therefore act in a manner that does not bring the organisation into disrepute and apply the
principles of good practice set out above.
When correcting errors about the CQC, employees must be transparent about whom CQC
is. Criticism of CQC should never be removed. The CQC Media Team can advise staff
about how to respond to legitimate criticism. CQC staff should also not remove derogatory
or offensive comments but should report them to the relevant administrators for them to
take action.
Before editing an online encyclopaedia entry about the CQC, or any entry which might be
deemed a conflict of interest, staff should check with their line manager and the
communications department before doing so.
Blogging and Micro blogging
Many bloggers, particularly in technical areas, use their personal blogs, and increasingly
their micro blogs like Twitter, to discuss their CQC work in ways that benefit the CQC, and
add to the “industry conversation”.
This guidance note is not intended to restrict this, as long as confidential information is not
revealed. Staff should be aware that if such information is revealed, it could potentially
constitute an act of gross misconduct.
Blogs, micro blogs or other personal websites which do not identify the blogger as a CQC
employee, do not discuss the CQC and are purely about personal matters would normally
fall outside this guidance.
Staff members who already have a personal blog, micro blogging or website which
indicates in any way that they work for the CQC, should discuss any potential conflicts of
interest with they line manager.
Similarly, staff members who want to start blogging or micro blogging, and wish to say that
they work for the CQC, should discuss any potential conflicts of interest with their line
manager.
If a blog makes it clear that the author works for the CQC, it should include a simple and
visible disclaimer such as “these are my personal views and not those of the CQC”.
However, the use of this disclaimer will not prevent disciplinary action where the
requirements of this policy apply.
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Personal blogs, micro blogs and websites should not reveal confidential information about
the CQC. This might include aspects of the CQC policy or details of internal CQC
discussion. If in doubt about what might be confidential, staff members should consult their
line manager.
Personal blogs, micro blogs and websites should not be used to attack or abuse
colleagues. Staff members should respect the privacy and the feelings of others – Please
refer to the CQC bullying policy.
If a member of staff breaks the law on their blog or micro blogs (for example by posting
something defamatory), they will be personally responsible.
If a member of staff thinks that something on their blog or micro blogs that may give rise to
a conflict of interest, impartiality, confidentiality, this must be discussed with their line
manager.
When a staff member is contacted by the press about their post on their blog or in regard
to their tweets that relate to the CQC they should talk to their line manager before
responding. The CQC press office must always be consulted.
Staff members are allowed to update their personal blogs or micro blogs from a CQC
computer at work, under the CQC’s Acceptable Use Policy for Internet and Email
(http://intranet.cqc.local/CQCIntranet/facilities--it/ict/use-of-internet.aspx).
Guidance for Managers on Blogging and Micro blogging
Under the guidance note, managers in each directorate will decide what is appropriate.
They should not adopt an unnecessarily restrictive approach. Managers should ensure
that any special instruction on blogging or micro blogging, are reasonable and explained
clearly to staff.
Managers should bear in mind concerns about confidentiality, conflicts of interest or
commercial sensitivity. In some cases individuals may be dealing with matters which are
so sensitive that the rules may have to set on what they can and cannot talk about on their
personal blogs or micro blogs and if in doubt they should seek advice from CQC HR and
Legal representatives.
Those involved in front line activities must take particular care to ensure that they do not
undermine the integrity of CQC or its output on their blogs or through Twitter.
If staffs are in doubt, they should refer immediately to their line manager; line managers in
any doubt should contact HR for advice.
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Equality Statement
CQC is committed to ensuring that all people management policies, and their application,
are free from any form of discrimination on the grounds of: age, disability, gender
reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and
belief, sex and sexual orientation.
CQC will monitor use of this Social Media Participation policy in order to identify whether it
is having an adverse impact on any particular group of individuals, and take action
accordingly.
Breaches of the policy
Members of staff should be aware that if they do bring CQC into disrepute it should be in
the knowledge that they face potential disciplinary action including dismissal for gross
misconduct.
There are internal mechanisms available if employees have views, complaints or
grievances.
Effective Date
This policy is effective from February 2013.
Review
This policy will be reviewed in light of changes to legislation and best practice that may
impact on the use of this policy and its associated procedure and guidance within CQC.
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Appendix
ACAS
www.acas.org.uk
ACAS stands for the Advisory, Conciliation and Arbitration Service. They provide
information about employee relations and independent advice. On their website you can
find guidance about dealing with work-related concerns, including policies on alcohol at
work.
Employee Assistance Programme
Line managers should also consider any additional support the employee may need and
should ensure the employee is aware of our free confidential helpline and personal
counselling service with First Assist http://www.first-assist.com/contact.aspx
Employees can access this service via a 24-hour free phone helpline, which is answered
by experienced external counsellors. They provide confidential advice and support for
callers on a wide range of issues. Telephone: 0800 716017
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