With the emergence of social media outlets (Facebook, Myspace, Twitter, etc), especially those used by social service providers, the importance of confidentiality is crucial. Below are some guidelines to consider when developing a social media policy of your own.

Supervised Visitation Program Guide for Developing Social Media Policy

Social media is an undeniable force in our new, global, and connected society. For those in the social services, social media both presents incredible opportunities and poses great risks. Supervised visitation programs are encouraged to develop a social media policy in order to maintain client confidence and confidentiality, guard the program’s reputation, protect staff/volunteers, and maintain high standards of ethical practice. Such a policy should be updated at least annually, because of the speed at which the technology is changing.

 I.   What is social media?

A. Definition

• • Social media is any online mode of communication used by individuals for the purpose of social interaction and networking.

B. Examples of social media include:

• • Facebook, MySpace, Wikipedia, You Tube, Twitter, Yelp, Flickr, Second Life, Yahoo groups, WordPress, Blogspot, etc.

II.   Why should supervised visitation programs develop a social media policy? 

A. Protection

• • Protecting clients’ personal information

1. Scenario: Thomas just started a blog, which he writes late at night. He has a username and feels almost anonymous, except to his family and close friends. He thinks that finally he has a safe place to vent about all the families he sees at the supervised visitation program, how he feels about his coworkers and how his job affects him on a daily basis. He gets lost in the relief of sharing all of his pent up feelings and frustrations. Over time, he starts using first names, giving details, revealing his inner thoughts and intentions. Then, one day, a client stumbles upon his blog.
2. Consider how a client might feel seeing his/her confidential information on the internet. Consider how the judge would feel about Thomas’s actions. This scenario illustrates how one individual can threaten the integrity of the entire program.
3. The internet can sometimes feel like a safe haven for venting and sharing about one’s experiences, but when supervised visitation staff/volunteers share (“chat” or “post”) about their day on the internet, they are violating clients’ rights to confidentiality, putting themselves at risk of disciplinary action, endangering the integrity of the program, possibly exposing the program to a libel suit, and perhaps influencing the litigation.

• • Staff/volunteer safety

1. Scenario: Sharon is an employee at a supervised visitation program. She proudly advertises the name of her agency and is constantly updating her Facebook status with things like “Wow, today was a hard day. Seeing so many screwed up families is really tough. This one little boy and girl I saw today have a real loser for a dad. Poor kids.” The “loser” happens to be a friend of a friend on Facebook, unbeknownst to Sharon, and was snooping around on her site. He is infuriated by this post, which he assumes refers to him, and decides to do something about it. He notices Sharon often has her daily routine on Facebook, including when and where she takes her kids to school…
2. Possible repercussions of Sharon’s actions?

a.  Threats to her/her family
b. Physical violence or stalking
c. Legal repercussions against both her and the program for which she works
d. Loss of employment

3. Social media policy is essential for protecting staff/volunteers from putting themselves at risk by provoking clients and divulging too much personal information.

• • Protecting the program

1. Misrepresentation

a. Staff who use social media and discuss work are representing their agency, often poorly and unprofessionally. This can lead to misunderstandings and even legal repercussions.

2. Losing respect and credibility

a. Unprofessional behavior by staff/volunteers on social media sites can give the agency a bad reputation and endanger credibility.
b.The funders of the program might decide not to renew the program’s contract if they believe that standards of confidentiality and professionalism are not maintained.
c. Scenario: Julie is a recent college graduate. She loves working in the child welfare field and enjoys getting to know families who come into the program. Two of the teenage girls who visit their father at the visitation program find Julie on MySpace. They ask to be friends. Julie she thinks this will be a good way to get to know them better and develop a good relationship with them. She fails to remember all the pictures on her MySpace from her crazy college days- at the beach on Spring Break and at various frat parties. She also is very open about her night life, and one of the girls has asked her about “clubbing” at the visitation program. Now Julie is being treated differently by the family. They have mentioned Julie’s postings to the program director.
d. As illustrated above, mixing personal and professional lives can invalidate staff/volunteers’ credibility and undermine the agency’s reputation.

3. Lawsuits and other forms of legal retribution

a. Agencies could be held accountable for staff/volunteers’ behavior on social media sites, even legally, especially if clients’ confidentiality is violated. The program can be held in contempt of court for confidentiality violations.
b. The vast majority of cases are referred to supervised visitation through the child protection and/or court system. This means that the cases sent to the program are part of ongoing litigation. Case-specific postings on social media sites might become part of the parents’ complaints against each other and/or the program.

B. Professionalism

• • Program staff/volunteers are not only bound to the law, but to professional ethics. These include-

1. Treating clients with dignity and respect.
2. Honoring clients’ rights to confidentiality.
3. Maintaining appropriate boundaries with clients.

• • Representing oneself online (in the public sphere) should be done with the same level of professionalism displayed in any public arena.

1. If you would not walk around the office in a bikini, tell everyone around the office exactly what you think of them, or air your dirty laundry publicly- you should not do it online!

III.   Who decides what each program’s social media policy should be?

A. Each organization must follow its own protocols for developing new policies.

B. If the program is under the umbrella of a larger agency, the program director should identify what the corporate policies are regarding social media.

C. If no corporate policy can be found within the larger organization, the program director should find out whose approval is needed to create a new policy at the local level.

D. If the program director is the head of the 501(C)(3) agency, it is his or her responsibility to evaluate alternatives and make choices regarding the program’s social media policy with the Board of Directors.

IV.   What are the possible components of a social media policy?

A. Affirmation of social media’s potential for good

• • Affirmation is important, as the agency does not want to seem disconnected and out-of-touch with technological advancement or opposed to change.
  • Social media should be affirmed as an exciting new part of our world and an opportunity to better serve the community, if care is used.

B. Advising staff/volunteers of general web safety precautions, such as:

• • Take advantage of opportunities social networking sites offer to protect personal privacy and information.
  • Remember that the information posted online, even when privacy settings are utilized, is potentially available to anyone with access to the internet. It is public information (comparable to writing your personal information on a billboard on I-75).
  • Take precautions to assure that potentially dangerous information is not displayed on your social media sites (i.e., personal activities, schedule and whereabouts, address, telephone number). The list might also include email, children’s names or activities, etc.).

C. Addressing basic ethical considerations, such as:

• • Staff/volunteers are expected to abide by social media site’s policies and terms of service.
  • Staff/volunteers are expected to comply with the law, as with copyrights and plagiarism.
  • Staff/volunteers are expected to behave professionally and ethically (i.e. not making defamatory comments, racial slurs, offensive language etc).

D. Issues specific to supervised visitation staff/volunteers, such as:

• • Staff/volunteers should be advised whether or not they are permitted to use the agency’s name and/or their job title on social media sites.
  • Staff/volunteers should be reminded of their commitment to confidentiality and instructed that they are prohibited from disclosing clients’ names, personal information and/or discussing client situations on social media sites, just as they would be in any other social context.
  • Staff/volunteers should be instructed that in order to avoid conflict of interest situations, they should refrain from interacting with clients and/or anyone related to clients on social media sites (this includes being friends on Facebook, sharing blog posts, etc.).
  • Staff/volunteers should be advised to refrain from discussing their workwith people on social media sites, especially with friends with whom there could be a potential conflict of interest.
  • Staff/volunteers should be encouraged not to “vent” about work on social media sites, but to find other, more private and professional ways of processing their work experiences, such as with a trusted colleague or the program director.

E. Clarifying information if programs allow employees to use the agency name/job title in social media:
If agencies decide to allow staff/volunteers to post their information on a social networking site, agency decision makers and policy makers need to decide what information is acceptable and unacceptable for those staff/volunteers to broadcast.

• • A list of acceptable and unacceptable examples may be helpful for staff to understand the boundaries of permissible online activity.
  • The consequences of mixing personal and professional lives should be described.
  • Conflict of Interest should be discussed.

1. Inadvertently creating a conflict of interest is a huge risk when using social media

a. Scenario: Jim is talking wall-to-wall on Facebook with a friend going through a messy divorce. In the course of comforting her, he confides that he works for a supervised visitation program and he can help her through the process if the judge refers her family to the program.
b. In the above scenario, Jim may be perceived by his friend’s ex-spouse as offering a special, biased relationship to a potential client.
c. This kind of situation can easily happen when personal and professional lives become too mixed on social media sites.

• • Other risk factors:

1. Potential endangerment of their safety and/or their families’ safety.
2. Heightened caution and restriction regarding the content of their social media site.
3. Heightened risk of employment loss and other work-related consequences.

V.   When should a social media policy be updated?

As technology changes, social media policies should be updated to reflect those changes.

VI.   What are the consequences of failing to adhere to the program’s social media policy?

A. Specific consequences actions for violation of the policy should be clearly communicated to staff/volunteers and executed consistently.

B. If your agency develops a social media policy, have all staff/volunteers review and sign upon hiring.

C. Add your policy and reminders about social media policy to the program’s Code of Ethics.

VII.   Who is responsible for handling questions, concerns and case-by-case ethical dilemmas?

A. It is important to designate someone to whom staff/volunteers can be referred if they need additional information.

B. The name of this designated person and their contact information should be included in the social media policy.

SAMPLE TEMPLATE

Sunshine Visitation Program’s Social Media Policy

An Introductory Statement should spell out the tension between the benefits and risks of social media.

I.   General web safety precautions:
This is a list of general safety precautions that you want your staff/volunteers to understand.

II.   Ethical considerations:
This is a list of ethical considerations concerning social media, program policies, and general ethical conduct.

III.   Issues specific to supervised visitation staff/volunteers:
This is a list of issues that deal specifically with the mission and goals of supervised visitation and with your program’s business ethics.

IV.   Acceptable vs. unacceptable use:
This section determines whether staff/volunteers are able to identify their agency name and job title in a social media site. It describes what kinds of information can be communicated on social media by staff/volunteers. It also lists prohibited communication.

V.   Consequences of failing to adhere to the programs’ social media policy:
The consequences of failing to adhere to the program policy, and the authority and discretion of the program director to take action when staff/volunteers commit breaches of the policy, should be outlined. The program contact for questions relating to the social media policy should be identified.