DEPARTMENT: All departments / EFFECTIVE: July 21, 2010
APPROVED BY: Lynn Stambaugh, CEO / REVISED:
Purpose:
The boundaries between personal and professional have become increasingly blurred due to the growing prevalence of internet-based social media, including interactive websites such as Facebook, MySpace, LinkedIn and Twitter. While social media outlets may be excellent platforms for employees to network and promote their employer’s business, a myriad of problems may result from an employee’s improper or unlawful use of a company’s name, reputation or confidential information while using such social media. As a result, Culbertson Memorial Hospital (CMH) is implementing this policy to guide its employees in responsibly and lawfully using social media.
Policy:
In general, CMH views social media sites (e.g., MySpace, Facebook, Twitter, Flickr, etc.), personal web sites, and blogs positively and understands that its employees use them as a medium of self-expression. However, employees need to understand that their actions, captured via images, posts, or comments can reflect on CMH. If an employee chooses to identify himself or herself as an employee of CMH on such Internet venues, some readers of such Web sites or blogs may view the employee as a representative or spokesperson of CMH. Therefore, employees should make every effort to use common sense and sound judgment about anything they post on social media sites.
Culbertson Memorial Hospital may from time to time establish and maintain an organizational presence on popular social media sites and through blogs. This presence will facilitate expanding communication opportunities for patients, employees, and other members of the communities served by CMH.
Procedure:
Guidelines for Personal Social Networking:
1. Follow all applicable CMH confidentiality policies. Employees are not to share confidential or proprietary information about CMH and are to maintain patient and employee privacy. Employees are not to post pictures or any other information that could identify patients directly (name, social security number, etc.) or indirectly (date of birth, diagnosis, etc.) on a Web site.
2. Properly identify yourself. When an employee’s connection to CMH is apparent, he or she needs to make it clear that he or she is speaking for himself or herself and not on behalf of CMH. It is recommended that the employee include this disclaimer: “The views expressed on this (blog, website, etc.) are my own and do not reflect the views of my employer.” Consider adding this language in an “About me” section of the blog or social networking profile. The use of CMH logos, trademarks, or intellectual property is not allowed without written permission of the CEO and/or their designee.
3. Make no reference to any patient(s) of CMH. Schuyler County is a small county in which most people either know, or know of, one another. It is likely that a patient referred to on Facebook, MySpace, a blog, etc, even if not by name, will be recognized by some visitors to the social networking site. Therefore, CMH employees are prohibited from making any reference to services being rendered to any patient of CMH or the fact that any person, even if not mentioned by name is receiving services from CMH. Therefore, even given the description of an unnamed patient’s condition will violate this policy. Making reference to any patient, whether or not by name, is not only a violation of this policy but, a violation of your confidentiality agreement, CMH’s policy on patient privacy, as well as HIPAA.
4. Be careful. Employees need to remember that what they post will be around for a long time, so they need to consider the content of their posting carefully and be cautious in disclosing personal details.
5. Be respectful. Employees are to be respectful in all communications and blogs related to or referencing the organization and/or other employees. Employees are not to use obscenities, profanity, or vulgar, defamatory or threatening language when referencing the organization and/or other employees. Employees are not to use blogs or personal Web sites to harass, bully, or intimidate other employees. Behaviors that constitute harassment and bullying include, but are not limited to, comments that are derogatory with respect to age, ancestry, national origin, race, religion, gender, sexual orientation, marital status, color, or disability; sexually suggestive, humiliating, or demeaning comments; and threats to stalk, haze, or physically injure another employee. Employees are prohibited from gaining or attempting to gain unauthorized or unlawful access to another employee’s private and secure social media platform, which may be a violation of the federal Stored Communications Act and various state privacy laws.
6. Do no harm to Culbertson Memorial Hospital’s reputation. Employees are not to use blogs or personal Web sites to belittle Culbertson Memorial Hospital. Employees are prohibited from using CMH computers or other equipment to conduct any commercial activity unrelated to Culbertson Memorial Hospital.
7. Do not interfere with work commitments and job duties. Social media activities should not interfere with work commitments and job duties. Culbertson Memorial Hospital reserves the right to lawfully monitor employee’s use of social media to protect legitimate business interests.
Guidelines for Official Culbertson Memorial Hospital Participation
1. Some CMH employees and staff members may be asked to participate on behalf of CMH. Any establishment of external sites representing CMH or social media participation on behalf of Culbertson Memorial Hospital is prohibited unless pre-approved and coordinated by the CEO and the Director of Community Relations. All use of external websites for work-related purposes, (such as photo sharing through Flickr.com, video sharing through Youtube,com, and blogging through websites or twitter.com) are to be pre-approved by the CEO.
2. Social networking activities on behalf of CMH are to comply with all CMH policies and guidelines.
3. Prior to sharing patient identifying health information or images through social media and blogs, the Director of Community Relations shall obtain a written authorization for the use and disclosure of the information from the patient/or their legal representative and the written approval of the CEO. All uses and disclosures of patient identifying health information shall be carried out in a manner compliant with applicable patient privacy policies, regulations, and standards.
The absence of or lack of explicit reference to a specific site does not limit the extent of the application of this policy. Where no policy or guideline exists, employees should use their professional judgment and take the most prudent action possible.
Any employee found to be in violation of any portion of this Employee Social Networking policy will be subject to immediate disciplinary action, up to and including termination of employment. Inappropriate disclosure of patient or employee information may also result in civil and criminal penalties for patient/employee privacy breach.
Employees who become aware of violations of this policy are to bring such information to the attention of his/her supervisor or manager. Supervisors and managers are to bring this information to the attention of the CEO.
Culbertson Memorial Hospital will not be responsible for any employee posting on any social media site not approved by the CEO. Employees are responsible for reading, knowing, and complying with the Terms of Service of the sites they use. Questions concerning this policy should be brought to the attention of the Director of Community Relations.