Social Media Policies for UCSF Hosted or Branded Accounts
Social media and blogging are important communication platforms to help tell the UCSF story. Through institutional participation in online media, the UCSF message can reach wider audiences and UCSF can impact more lives, but these channels come with their own risks and liabilities.
Why we need guidelines
UCSF has policies and guidelines for the use of online media to ensure that laws are being followed and that the University is being accurately and consistently represented in such communications. University employees who participate in the online world in an official capacity should understand the impact of using these tools to communicate about the work and mission of UCSF. These guidelines apply to all members of the UCSF community participating in university-branded or -sponsored blogs and social media.
Personnel looking for guidance regarding individual participation in social media may also reference the university’s Social Media Policies for Personal (i.e. Non-UCSF hosted) Accounts.
Please note that all UCSF personnel must abide by UCSF policies and guidelines including, Campus Administrative Policies, the Campus Code of Conduct, Local and Campus Policies, and UCSF Brand Identity Guidelines.
Definitions
UCSF-Sponsored Site:
Official blogs and social media sites operated by UCSF departments or schools, approved by the deans, chairs and/or administration, and coordinated by the Office of Communications or UCSF Health Marketing.
Non-UCSF-Sponsored Site:
Any site not operating under the purview of the UCSF Office of Communications or UCSF Health Marketing, or under the oversight of UCSF deans, chairs and/or administration.
1. Official University-sponsored blogs and social media
These guidelines cover all types of University-sponsored blogs and social media, including those that educate on disease states, such as the Memory and Aging channel on YouTube, and those that promote a program or provide school information. Examples include the UCSF Imaging Twitter account and the UCSF Library Archives Tumblr feed.
If you are participating in a UCSF-sponsored blog or other social media representing the University, it is important that you follow certain guidelines and obtain specific approvals.
Email University Relations for details on approvals, legal responsibility, privacy policies and logo usage. Note that all UC, UCSF, school and department policies and guidelines related to privacy, logos, intellectual property, etc. apply to these communications media.
Special note for student government and registered campus organizations: Student organizations must observe University of California Policies Applying to Campus Activities, Organizations, and Students, which can be found here. For rules regarding use of the University of California name, please refer to Appendix B.
For inquiries regarding UCSF Medical Center and UCSF Benioff Children's Hospitals, email UCSF Health Marketing.
For faculty- or other UCSF-sponsored blogs or other social media sites, please contact the Office of Communications and observe the following guidelines:
1a. Approvals
Your department chair or dean must approve a University-sponsored blog or participation in social media. The sponsoring department or school is responsible for ensuring that if the website contains any personally identifiable or protected health information, it is compliant with all privacy laws. The sponsoring department or school is responsible for ensuring that the content of the website is appropriate and does not cause damage to UCSF’s reputation.
1b. Consent
If you plan to post photos or videos, or patient information in any format, including written, you are responsible for obtaining appropriate authorization and consent forms from all such persons in the photos or videos, including patients, employees, faculty, staff, students and visitors.
- If you have any questions about authorization or consent related to news media, please contact UCSF News Media (476-2557).
- If you have any questions about consent, please contact Medical Center Risk Management (415-353-1842). If you have any questions about privacy laws, contact the Privacy Office (415-353-2750) or the Office of Legal Affairs (415-476-5003).
All consent forms must be maintained in the department or the patient’s medical record for six years after the last day the site is active.
If your site includes any information regarding disease states, treatment avenues, clinical trial research, or other information of interest to a patient audience, the site must include disclaimer language. Please consult with the Office of Legal Affairs for appropriate language.
- Remember, even if you refrain from mentioning a patient by name on a social media site, if there is a reasonable basis to believe that the person could still be identified from the information you have shared, then its use or disclosure could constitute a HIPAA/Privacy violation, resulting in personal and UCSF liability, penalties and fines.
- Closed groups and private messages on social media channels (such as Facebook chats or Twitter direct messages) are not secure channels for communication, and should not be used to communicate with or about patients.
1c. Comments on social media sites
If you plan to include the ability of the public to comment, please contact the Office of Legal Affairs (415-476-5003). You should be aware that, because of UCSF’s status as a public entity, creation of any public discussion forum may invoke free-speech issues, thereby limiting your ability to edit the content of comments made by the public. Threatening or obscene comments may be deleted, as may spam, posts promoting illegal activities or copyright infringements. However, complaints about the university, its employees, its facilities or practices may not be deleted without approval from UCSF legal counsel.
If you plan to include the ability of the public to comment, you must include disclaimer language. Please consult with the Office of Legal Affairs for appropriate language.
You may also receive comments or messages from individuals seeking healthcare information or guidance. UCSF’s social media channels cannot be used to solicit health-related information from a user, such as asking someone to clarify a health issue. UCSF’s social media channels also cannot be used to offer diagnostic or treatment advice, such as recommending that someone take aspirin for a headache. In situations in which someone asks for guidance on a health-related issue, you can direct the person to a UCSF clinic to make an appointment or recommend that they contact an authorized healthcare provider.
1d. Advertising
Selling of advertising by departments or programs is prohibited on UCSF-sponsored blogs or social media sites. Departments and programs using blogs and social media should not include content that could create any impression that UCSF is endorsing a particular product or service.
1e. Abiding by the UCSF Campus Code of Conduct
The UCSF Campus Code of Conduct articulates the values and ethical practices collectively embraced by the UCSF campus community. It is the expectation that all members of the campus community will exercise integrity and highly ethical conduct when using social media. Included in the Code of Conduct, and particularly important in social media, is respect for copyright laws.
Trademark and copyright laws apply to social media in most of the same ways that they apply to traditional publishing. Citing the source of an image, audio track or video does not substitute for obtaining permission. Failure to obtain permission to use a copyrighted photo could result in legal action.
See the complete UCSF Code of Conduct Campus Policy. The Code of Conduct, along with school and department-level Code of Conduct standards, applies equally to content and use of UCSF-sponsored blogs and social media.
1f. Content suspension
The University reserves the right to suspend the use of or modify content on UCSF-sponsored blogs and social media sites within University policy and applicable law.
1g. Monitoring and Updating
The owner of the site (assigned by the department chair) is responsible for monitoring, maintaining and updating content to ensure accuracy and for addressing public comments as they arise.
2. Representing UCSF in social media
There are times when UCSF representatives speaking for UCSF will want to publish comments on others’ blogs, channels or posts in order to correct misstatements of facts about UCSF or its programs, or comment on issues that are being reported in the press. These types of posts should be made only by or in consultation with the Office of Communications or other key University communicators to ensure that UCSF is speaking with one voice on issues of public concern. All postings of this type should clearly identify the poster as an employee of UCSF who is speaking on behalf of UCSF.
UCSF employees who choose to comment as an individual on issues affecting or involving the University should make clear that their comments do not represent the University’s position or voice. Example: “All comments made here are made in my individual capacity and not on behalf of UCSF, and are not reviewed or approved by UCSF.” [See Social Media Policies for Personal Accounts]
If you have any questions about these UCSF guidelines, please contact the Office of Communications or the Office of Legal Affairs (415-476-5003).
References:
UCOP Electronic Communications Policy
UCSF Brand Identity Guidelines