Social media policy
Social Media Policy 2023-26
- Introduction
1.1 Westward uses social media as a way to connect with customers and other stakeholders and to share information about the organisation and other relevant topics of interest.
1.2 This policy applies to all customers and colleagues of Westward Housing Group Ltd. Board members are managed through our governance and communication policies.
1.3 Westward social media channels provide information about events, useful films and links, and a means to be involved with Westward.
1.4 Site users are able to contact Westward in private by direct messaging us with feedback, requests or concerns.
1.5 This policy is supported by Social Media Policy Guidelines for practical application.
1.6 Both policy and guidance will be published on our intranet and website. - Objectives
2.1 To provide clear internal and external customer accountability.
2.2 To ensure that colleagues engage appropriately with our social media channels.
2.3 To outline how we use social media platforms to proactively engage with our audiences.
2.4 To support another means of direct customer contact with Westward through private messaging of feedback, requests or concerns. Customer hub advisors to be trained to handle these direct as part of customer connect project, skills include a different way or responding in terms of speed, tone and language.
2.5 To mitigate risk factors that may arise through our social media platforms. - Policy Details
3.1 Westward is committed to making the best use of technology to improve the way we provide services, communicate and interact with our communities.
3.2 Westward recognises the communication benefits of social media in customer accessibility, public relations, reputational, sales and customer engagement.
3.3 Social media offers us an opportunity to build relationships with customers by listening to and learning from them. It can encourage traffic to our website and enhance our brand.
3.4 Westward encourages all colleagues to use social networking for business purposes to promote our services as well as to engage from their own accounts where appropriate.
3.5 Social media is the preferred communication method for many of our customers and we will provide a positive and responsive experience.
3.6 All queries and complaints will be responded to within half a working day.
During periods of extended business closure e.g. Christmas, we will post content in advance advising of the out of hours approach.
3.7 Our tone of voice on social media will reflect that we are friendly, professional and helpful. We will have a balanced mix of posts including useful information, corporate messages and human interest stories.
3.8 Customers should feel listened to and have a positive customer experience to encourage customer engagement.
3.9 We provide clear terms of use on our platforms which encourage users to engage in a constructive way e.g. to prevent bullying, harassment, hate crime and disrespectful behaviour.
3.10 Westward’s reputation will be positively promoted in meaningful ways.
3.11 Westward will encourage private messaging to keep personal data and sensitive discussions away from public view. - Professional Conduct
4.1 Social media posts reflect on the company and are part of Westward’s reputation. Colleagues are responsible for their conduct and are required to comply with the Professional Boundaries policy and Standards of Conduct and Probity policy (staff).
4.2 Any posts made by colleagues reflect on Westward if they can be linked to Westward in any way; regardless of whether they are made in work or personal time and from work or private devices.
4.3 Any breach of this policy may result in disciplinary proceedings.
4.4 Colleagues must not share any personal data relating to themselves or others, other than images, on Westward social media accounts. For their own security and protection they are also strongly advised to use high level privacy settings on personal accounts.
4.5 This policy prohibits the posting by colleagues of any social media content which:
• Contains illegal material
• Breaches regulatory rules or procedures
• Contains material which is defamatory to or damages Westward’s reputation
• Brings Westward into disrepute
• Breaches Westward policies
• Is discriminatory, slanderous or libellous
• Amounts to bullying or harassment
• Contains confidential information belonging to Westward or its customers
4.6 Colleagues must:
• Be professional and responsible
• Provide content which adds value, is relevant, engaging, accurate and assists Westward’s purpose, objectives and values
• Have clear aims, assess risk and monitor success
4.7 If colleagues have Westward customers as social media contacts and were to share anything inappropriate or in breach of Westward policies, then this will be treated as a disciplinary matter.
4.8 Where colleagues have an association to Westward online, they may be considered to be acting in the course of their employment. Any content which breaches Westward’s policies, such as discriminatory or bullying content, will be investigated under Westward’s Disciplinary Policy.
4.9 Westward may review information in colleagues’ social media pages.
4.10 Images of customers posted on Westward social media must have a signed Image Consent form. - Business aims met by using social media to:
5.1 Provide fast and good value information services.
5.2 Engage customers using posts of general interest and benefit as well as organisational messages.
5.3 Provide an informal, engaging ‘human’ voice for the organisation to enhance customer relations and experience.
5.4 Increase customer feedback and a two-way dialogue to engage with customers.
5.5 Increase positive awareness of our organisation, brand, activities and services.
5.6 Listen to and better understand our stakeholder groups, as well as identify which communities are talking about us and what they are saying.
5.7 Extend reach of corporate messages online, measured by followers and web traffic referrals from external sites.
5.8 Be accessible and reach a wider audience, including hard to reach groups.
5.9 Provide a free and real-time method of communication, invaluable with urgent messaging e.g. a service disruption. - Regulation
6.1 Colleagues must approach the Communications team to be an author on Westward social media sites.
6.2 Colleagues must contact the Communications team for guidance and approval to create a new Westward social media site including project-based closed groups.
6.3 Communications team must be informed of any colleague with a work social media account and of any social media work account so a central list can be kept for account holder management, especially if colleagues leave the organisation.
6.4 Comms will update the IS team with any new social media work accounts. IS team will inform communications team if a colleague with social media access is no longer employed as soon as they are made aware by People team, so that any administrative access to Westward social media sites can be revoked.
6.5 Copyright, intellectual property and data protection laws must be complied with.
6.6 Social media accounts should only be created with the prior knowledge and approval of the communications team.
6.7 Any colleague setting up a business profile on social media using the term ‘Westward’ or ‘Westward Housing’ in the url may only do so with prior permission of the communications team. A list of these will be kept so that former employees’ accounts can be closed. The Westward logo is not to be used for the profile image or cover photo.
6.8 Where the communications team does not directly manage or own a page, then they must be given administrator access to and have oversight of the page enabled. This manages the risk of an emergency where the main adminstrator may be absent.
6.9 Any colleague that manages a social media account for Westward must have relevant training from the communications team such as image consent and the organisational approach to handling online abuse.
6.10 Social media sites should signpost customers to the Westward website and encourage registration for a self-service MyAccount.
6.11 Westward social media sites are to carry the approved terms of use notice regarding acceptable and expected behaviour.
6.12 General complaints, feedback and comments that may be negative should be addressed promptly, politely and helpfully; then proactively taken into private messaging.
6.13 We reserve the right to remove comments / content which is deemed inappropriate or discriminatory. Derogatory or offensive comments will be removed by the administrator and a message posted advising that all such comments will be removed and the reasons. An extreme or persistent offender will be blocked from the site, template text is available in the Social Media Policy Guidelines. - Responsibility of colleagues on work social media
7.1 You are responsible for any content you publish; be mindful that it is in the public domain and may always exist even if you delete it.
7.2 Staff administrators and site members must have work accounts, not use personal accounts.
7.3 Any accounts used for work social media must have multi-factor authentication enabled for log in and when posting (you must use a work device to access it) and complex passwords in line with the IS usage and device policy.
7.4 Never share personal or sensitive data or confidential information unless private messaging.
7.5 Customers should not share their personal data with us across social media channels except when private messaging. Colleagues will remove any instance where this happens and explain the safety reasons to the customer.
7.6 When filming or photographing for social media upload ensure you have cleared the background of identifying features such as family photographs.
7.7 Always consider personal safety on social media, do not publish any personal information.
7.8 Be professional by being honest, accurate and responsible.
7.9 Work social media sites must be monitored and responses provided within each half working day and fresh content added several times per week.
7.10 Always use appropriate language, tone and conduct.
7.11 The line manager of any departing staff member is responsible for ensuring they are removed from access to the social media site. - Responsibility of colleagues on personal social media
8.1 Colleagues at Westward are expected to be aware of their personal and professional conduct at all times, even where this extends outside of the workplace.
8.2 Anything a colleague says on social media should be something they are prepared to say to customers or peers. If there is any doubt, then it should not be said. Social media can be fast and reactive but colleagues need to be careful what they post.
8.3 Colleagues should always consider personal safety on social media, it is advisable not to publish any personal data, location, work routines, holiday dates, family photos etc.
8.4 When posting in a personal capacity on social networking or blogging sites, colleagues should:
• Understand that they are responsible for any content they publish
• Understand and use highest online privacy settings
• Make it clear when referring to a topic related to their employment or a service Westward is associated with, that views expressed are personal ones and not linked to Westward
• Not harm Westward’s reputation. Derogatory comments about the organisation can lead to disciplinary action
• Online commentary never disappears, deleting them does not mean they are gone or have not already been seen and shared
• Where colleagues publish an association to Westward or make any reference from which an association to Westward could reasonably be construed, they may be considered to be acting in the course of their employment, in which case anything posted will be directly governed by Westward’s policies. Any content which breaches Westward’s policies, such as discriminatory, harassment or bullying content, may be treated as a disciplinary matter
• Any breach of customer confidentiality online will be treated as a disciplinary matter - Closed company networking groups
9.1 Confidential information, intellectual property, or information about customers, is not to be discussed by site members who have authorised access to the information, as other members may not.
9.2 Where closed internal groups are established by colleagues on social networks such as What’s App, the informal nature of them means it is easy for colleagues to develop a casual approach to what they say. Inappropriate comments about colleagues or customers are not to be made.
9.3 Colleagues will be held accountable for tone and content on these sites, bullying and harassment will not be tolerated.
9.4 The same terms of use on Westward’s external social media sites apply to these internal platforms. - Copyright and other legal issues
10.1 Copyright may exist in relation to anything e.g: a company logo on a building in the background or music on a film.
10.2 Colleagues must comply with the law in regard to copyright and plagiarism.
Defamatory statements can lead to lawsuits against the author, which mean company reputational damage. Posting of someone else’s work without permission is not allowed (other than short quotes that comply with the ‘fair use’ copyright exceptions).
10.3 Colleagues must comply with the laws regarding libel, slander and defamation of character.
10.4 Any image of a person who is not a member of staff, where they are identifiable, must have a signed image consent form covering use of it. These can be held for three years according to our retention schedule. There are key historical retention exceptions which are covered in the Data Protection Policy. Colleagues consent to have their image used for internal communications purposes as part of their role. Colleagues must be asked to give specific consent for use of their image if it is for external media such as
social networks, website or external publications. Verbal consent is acceptable. - Monitoring and Review
11.1 The Social Media Policy is a mandatory read document. All colleagues are required to read and comply with it.
11.2 Social media is monitored and reported on by the communications team.
11.3 This policy will be reviewed every three years unless legislation or best practice agreements change. - Budgetary, Financial and VFM Implications
12.1 Social media has significant cost benefits over other forms of bulk communication, it is cost-free except for employee time. - Risk Management
13.1 The Social Media Policy seeks to address risk around safety to individual colleagues, the organisational reputation and safety of customers when using our social media sites.
13.2 Complaint or protest sites in relation to Westward, set up by external parties including customers, will be monitored by the communications team and considered periodically with relevant directors. - Health and Safety
14.1 This policy aims to mitigate risk to safety of users on our social media sites and from cyber bullying. - Equality, Diversity and Inclusion
15.1 This Social Media Policy supports Westward’s commitment to treat all people with fairness and respect. We aim to foster good relations within our communities. When applying this policy we will act sensitively towards the diverse needs of individuals and to reduce discrimination and harassment by providing this means of accessible communication between Westward and its diverse customers.
15.2 We will be inclusive and help ensure representation of diversity of our communities in our imagery and content. - Environmental sustainability
16.1 Social media is a paper free means of communication, supporting our carbon reduction goals. - Consultation and Customer Engagement
17.1 Customers were involved in this policy review through feedback from the 2023 communications survey.
17.2 Scrutiny group and communications group customers were consulted and scrutiny group members regularly feature on our social media in films and articles.
17.3 Live chat option on Facebook has been used previously but did not take off, being considered again in consultation with other housing associations using it successfully.
17.4 The staff forum was consulted. The governance team including the data protection officer were also consulted.