Manager's Toolkit
The UMHS Use of Social Media for Business Purposes policy:
- Assures compliance with regulatory, state and federal laws
- Seeks to maintain consistency with institutional communications goals related to external communications
- Establishes procedures for seeking authorization, creating, monitoring and maintaining social media on behalf of UMHS
- Provides guidelines for professional and personal activity online
- Defines who is permitted to create and manage social media on behalf of UMHS
- Defines who is authorized to grant permission for opening an account on behalf of UMHS
The UMHS Use of Social Media for Business Purposes policy DOES NOT:
- Address the use of social media for internal communications unless the information is available to external audiences
- Provide the basis for policing faculty, staff or students’ personal accounts
- Address the use of social media for personal purposes so long as such personal usage does not violate existing law, such as HIPAA
- Establish restrictions on use at work, so long as use during work hours are in accordance with existing department and institutional policies
- Hold UMHS employees accountable for inaccurate information posted about them online by others
Ensure your unit/department is in compliance
Department leadership should do the following to ensure they and their department remains in compliance with the new policy:
- Thoroughly review the Social Media Toolkit and all applicable policies listed on this page.
- Make sure their official social media presences are registered with the Office of Public Relations and Marketing Communications by asking the manager or administrator of the platform to submit a request for each presence using the online Apply for or Registration an Account Form.
- Make sure all content managers/administrators of these sites have reviewed the Social Media Site Terms & Conditions and signed and faxed the Administrator Responsibilities Form to 734-615-2169.
- Make sure employees know that to create new social media sites or presences, a request must be submitted to Public Relations & Marketing Communications via the online Apply for or Registration an Account Form and approval must be given before they can begin.
Use of social media during work hours
A common concern among managers relates to how employees are using social media during work hours. The policy does not explicitly restrict access or use of social media. Nor are there plans in place to prohibit access to them from UMHS workstations. However, it is the expectation that employees' use of these resources do not interfere with their ability to perform tasks and duties required by their job. And, if a policy within a unit is in place that defines how or if employees are permitted to use such resources, employees are also expected to observe it. Managers should contact their unit's HR rep and/or the Compliance Office for guidance.
Handling complaints about your employees
Responding to complaints on social media sites about faculty, staff or students, or dealing with possible HIPAA violations, should be addressed in the same fashion as they do in any other circumstance by contacting Patient Relations and/or Compliance for guidance. Administrators and managers should also be aware of the steps required to capture posts and comments before they disappear from general view. Please refer to the Managing Negative Comments and Posts handout for proper capture procedures.
Study up on the issues
As a manager, you should also be aware of the legal implications of taking disciplinary actions against individuals who are using social media for personal reasons and understand the nuances between what's permitted by law and what's not permitted according to UMHS policy. Please review the following policies, guidelines and other resources thoroughly to prepare yourself for questions or concerns related to the new policy:
U-M Policy - Proper Use of Information Resources, Information
Technology, and Networks at the University
U-M Policy - Rules and Conditions of Work
UMHS Policy 01-01-040: Use of Social Media for Business Purposes
UMHS Code of Conduct
UMHS Code of Conduct Attestation
UMHS Policy 01-01-004, Signature Authority
UMHS Policy 01-04-002, Confidentiality of Patient Information
UMHS Policy 01-04-003, Outside Interests and Conflicts of Interests
UMHS Policy 01-04-005, Reporting Compliance Concerns
UMHS Policy 01-04-501, Information Security Systems Security Standards
UMHS Policy 01-04-502, Security of Portable Electronic Devices and Removable Media
UMHS Policy 01-04-520, Physical Security of Electronic Protected Health Information (ePHI) and Other Sensitive Data
UMHS Policy 03-07-015, Photographing, Recording and/or Filming of Patients
UMHS Policy 04-06-047, Disruptive or Inappropriate Behavior by UMHS Personnel
Legal, industry and HR considerations:
MHA Presentation on Social Media and Health Care (PPT)
AMA Policy Statement on the Use of Social Media
National Labor Relations Board Prosecute Charge Regarding Employer's Social Media Policy
Social Media Toolkit FAQ
MHA Social Media Legal Guidance and Template Policy (PDF)
Using Social Media in your Negotiations (internal-only, with permission. Do not distribute. PDF)
Request a presentation
Compliance Office speaks to employee responsibilities around social networking in Michigan Tradition and Values-new employee orientation. Units may also request a presentation from the Office of Public Relations by calling 734-764-2220, on the following topics:
- The Social Media Toolkit
- Social Media for Clinicians
- Managing Your Online Reputation
