The aim of this Policy is to set out a Code of Practice to provide guidance to staff and Parish Councillors in the use of online communications, collectively referred to as social media.
Social media is a collective term used to describe methods of publishing on the internet. The policy covers all forms of social media and social networking sites which include (but are not limited to):
Who does it apply to?
The principles of the Policy apply to Parish Councillors and all Parish Council Staff.
It is also intended for guidance for others communicating with the Parish Council.
The policy sits alongside relevant existing polices which need to be taken into consideration.
Use of Social Media
The use of social media may replace or complement existing forms of communication. The website and other forms of social media may be used to enhance communication. Therefore, existing means of communication should continue with social media being an additional option.
1. The Council will appoint a nominated member of staff/ Councillor or Councillors as moderator(s). They will be responsible for posting and monitoring of the content ensuring it complies with the Social Media Policy. The moderator will have authority to remove any posts made by third parties from our social media pages which are deemed to be of a defamatory, libel nature. Such post will also be reported to the Hosts (i.e., Facebook) and the clerk.
2. The Parish Council will appoint a nominated “Webmaster” to maintain and update the Parish Council Website
Social media along with the Parish Council website may be used to –
Facebook will be used to support the website information above.
Emails will be used to distribute information of council business.
Guidance for Councillors using the Council’s Social Media Presence.
Individual Parish councillors are responsible for what they post. Councillors are personally responsible for any online activity conducted via their published e-mail address which is used for council business. Councillors are strongly advised to have separate council and personal email addresses, and adhere to The Members’ Code of Conduct, see Guidance for Councillors at the end of this document.
3. All social media sites in use should be checked and updated on a regular basis and ensure that the security settings are in place.
4. When participating in any online communication:
5. Respect the privacy of other councillors and residents.
6. Do not post any information or conduct any online activity that may violate laws or regulations, see below libel and copyright.
7. Residents and Councillors should note that not all communications require a response.
8. The nominated moderator or moderators shall remove any negative posts which may contain personal and inflammatory remarks, libellous or defamatory information without further comment or notification.
9. Councillors or parishioners who have any concerns regarding content placed on social media sites should report them to the Clerk to the Council. Misuse of such sites in a manner that is contrary to this and other policies could result in action being taken.
10. The Policy will be reviewed annually.
Date of Approval by Council 26th July 2021
Additional background information (IDeA) 2010
Libel If you publish an untrue statement about a person which is damaging to their reputation they may take a libel action against you. This will also apply if you allow someone else to publish something libellous on your website if you know about it and don’t take prompt action to remove it. A successful libel claim against you will result in an award of damages against you.
Copyright Placing images or text on your site from a copyrighted source (for example extracts from publications or photos) without permission is likely to breach copyright. Avoid publishing anything you are unsure about or seek permission in advance. Breach of copyright may result in an award of damages against you.
Data Protection Avoid publishing the personal data of individuals unless you have their express written permission.
Bias and pre-determination If you are involved in determining planning or licensing applications or other quasi-judicial decisions, avoid publishing anything that might suggest you don’t have an open mind about a matter you may be involved in determining. If not, the decision runs the risk of being invalidated.
Obscene material Publication of obscene material is a criminal offence.
Electoral periods and purdah The Electoral Commission requires that candidates provide a return of expenditure on any form of advertising or campaign literature and that includes web advertising.
And there are additional requirements, such as imprint standards for materials which can be downloaded from a website. Full guidance for candidates can be found at www.electoralcommission.org.uk www.electoralcommission.org.uk/guidance/those-we-regulate/ candidates-and-agents
The council’s legal position Material published by a local authority as an organisation is, for obvious reasons, restricted in terms of content. It must not contain party political material and, in relation to other material, should not persuade the public to a particular view, promote the personal image of a particular councillor, promote an individual councillor’s proposals, decisions or recommendations, or personalise issues. Nor should the council assist in the publication of any material that does any of the above.
The Members’ Code of Conduct – Guidance for Councillors
NB The Localism Act 2011 placed a general obligation to “promote and maintain high standards of conduct by members and co-opted members of the authority “
Councillors can have ‘blurred identities, you may have a social media account where you comment both as a councillor and as an individual. Ensure it is clear when you are posting in a private capacity or as a councillor. Such blurred identities might for example have implications where your views are taken as those of your organisation or political party, rather than your personal opinion. There is the need to get social media accounts/ profiles clear, to be confident as to what you can and can’t say while you are representing the Parish Council. How you use your online identity will also determine how online content will be treated in respect of the Members’ Code of Conduct. Councillors may be communicating politically.
There is a difference between communicating on behalf of the council, for example blogging as a councillor or as a private citizen and the former will be held to a higher standard than the latter.
The key to whether your online activity is subject to the Code of Conduct is whether you are giving the impression that you are acting as a councillor. And that stands whether you are in fact acting in an official capacity or simply giving the impression that you are doing so. This may be less than clear if you have a private blog or a Facebook profile.
There are several factors which will come into play which are more a question of judgment than a hard and fast line. For example, a Standards Committee may consider how well known or high profile you are as a councillor, the privacy settings on your blog or social networking site, the content of the site itself and what you say on it. Most councillors are using their online profile to communicate with citizens about representing their local area so engaging the code, if necessary, should be a relatively straightforward decision. Since the judgment of whether you are perceived to be acting as a councillor will be taken by someone else, it’s safest to assume that any online activity can be linked to your official role. It is worth noting that web links to official council websites may give or reinforce the impression that you are representing the council.
Unless you’ve gone to significant effort to keep an online persona completely separate from your councillor identity, you are unlikely to be able to claim that you were acting in a completely private capacity. Members should comply with the general principles of the Code in what they publish and what they allow others to publish.
Some of the terminology in social media, like ‘following’ or ‘friending’ can imply an intimacy that’s not really there. Both terms just mean you have linked your account to someone else so you can share information. Savvy internet users are used to this, but some people can feel a frisson of unease when their council, local police service or councillor begins following them on Twitter before establishing some sort of online relationship. Some councillors wait to be followed themselves first. Do make use of other communication functions that social media allows you. Twitter’s ‘list’ function, for example, can help you to follow local people in a less direct way. And bloggers are invariably happy for you to link to them, so you don’t need to ask first in this instance. Social media is transparent. The best bloggers admit mistakes rather than try to cover them up (which isn’t possible online). Amending your text and acknowledging your mistake; by putting a line through the offending words and inserting a correction or providing an update section at the bottom of a blog post – shows you are not pretending it never happened and is much better than just deleting it when dealing with online misfires.