Social Media Guidelines for UF Health

GUIDELINES NUMBER W8
LAST UPDATED 7.15.2020

Guidelines Statement

Any UF Health unit may create and maintain social media sites for their respective programs, services, divisions and initiatives, as long as these accounts are used for appropriate official purposes and follow best practices and guidelines set forth by UF Health Communications. All accounts must be approved by UF Health’s Chief Communications Officer (delegated to perform this task by the UF Senior Vice President for Health Affairs / President of UF Health). These guidelines are additions to the UF Social Media Use, Guidelines and Policy Implications document on the UF HR website (http://www.hr.ufl.edu/emp_relations/policy/social_media.asp) and UF Health Shands Social Media Policy (HR#322).

Purpose

To promote effective and beneficial use of social media accounts by UF Health units.

Procedures

Purposes and goals of social media accounts

  • To increase awareness of our products, services, programs, providers and events through engaging content, including text, photos and videos.
  • To protect the space with our name and branding that will serve as a reliable source for health and system information.
  • To become more transparent to our customers and community and to engage in appropriate two-way communication with them.
  • To discover issues that are important to our customers and clients and to develop integrated communications strategies and responses around those issues.
  • To assist with development, fundraising and employee recruitment efforts.
  • To educate the community about new discoveries, technologies or clinical services in the UF medical community.
  • To assist in student, researcher and faculty recruitment for the health colleges.
  • To share research findings with the health care community, other research professionals, the general public and the media.

Developing social media accounts

  • UF Health Communications staff maintain flagship corporate accounts. Because social media updating and monitoring can be resource intensive, other departments are encouraged to submit content to UF Health Communications staff for distribution on flagship accounts. UF Health Communications staff may make determinations that some content does not align with institutional goals; they reserve the right to make decisions regarding the editorial calendar to meet those goals and to prioritize content based on organizational need.
  • Any UF Health unit may create and maintain social media sites for their respective programs, services, divisions and initiatives, as long as these accounts are used for appropriate official purposes and follow best practices and guidelines set forth by UF Health Communications. All accounts must be approved prior to creation by UF Health’s Chief Communications Officer (delegated to perform this task by the UF Senior Vice President for Health Affairs / President of UF Health) and accounts created by UF units also must receive prior approval from University Relations. See more information on starting an account, below. 
  • Accounts are to be used for communication with external audiences. Units are discouraged from using their social media accounts to communicate primarily to internal audiences (staff, faculty, etc.). Using social media accounts primarily for employee purposes is problematic because these platforms are controlled by outside companies and UF Health cannot guarantee the privacy of information sent via these platforms. Additionally, not all UF Health employees choose to use social media and units should not isolate those employees from internal communications by using these platforms.
  • After an account is approved, the unit managing the account must designate two or more unit social media managers responsible for administration of the page.
    • For social media platforms that have a single log-in account, the email address associated with the page must be an email alias that forwards mail to all of the unit’s social media managers.
    • Log-in credentials should also be provided to the UF Health social media team as a third back-up for account access.
  • Social media managers will receive training on best practices, writing for social media, content monitoring, social media risks and the basics of each social media platform. Training and support will be provided by the UF Health social media team.
  • Approved accounts will be listed on ufhealth.org and will be able to be linked to by department and unit websites.
    • UF Health flagship social accounts will only reshare or use content from approved UF Health channels.
    • By registering your page, you will have access to additional information, training and in-services, as well as a wider audience. In-services will be held every six months, and emails with tips and content suggestions will be sent out throughout the year. Registered pages will also receive support from their UF Health Communications representative, and from the UF Health social media team.
  • Social media pages are to be used for long-term communication plans. Units may not create Facebook pages exclusively for single events or short-term projects. Building an audience takes time, and these channels will have difficulty reaching a broad enough audience to effectively promote and reach their goals. Please contact your UF Health Communications representative or the UF Health social media team on how best to promote these such events or projects with our existing social media channels and/or other available communications tools.
  • Social media accounts must follow UF social media guidelines and policies, as well as these social media guidelines.

Social Media Account Auditing and Support

  • To help ensure official UF Health accounts follow guidelines and policies, one person from each college and from each official center, institute or Shands unit (the top communications professional for that entity, or his/her designee) will monitor the social media accounts operated by units of that entity (eg: departments, divisions, offices, unofficial offices/centers, etc.). This person will be called a “social media adviser” and will periodically check their assigned social media accounts for any issues or policy violations and will communicate with the social media managers of these unit accounts as needed. The adviser will also serve as a resource for the managers, offering guidance and tips as appropriate, and will check with each manager several times a year.
  • The UF Health social media team maintains a record of all approved UF Health social media channels, which includes the channel’s URL, the name of the social media account managers and the social media adviser.
  • The UF Health social media team will perform periodic audits of approved UF Health UF social media accounts several times a year and discuss findings with the appropriate social media adviser.
    • If a social media adviser or the UF Health social media team discover a page that isn’t following guidelines or has room for improvement, they will contact the social media account managers to discuss improvements and enhancements to their social content. They might be asked to attend further training and work with the adviser and social team on their editorial calendars to provide direct mentoring on content. If, following this training, issues persist, UF Health Communications might request that the page be removed or redirected to an alternate location that would better serve meeting the unit’s goals.
  • The UF Health social media team will hold biannual meetings with social media managers and advisers to discuss strategy, best practices, new trends, etc.
  • In the event that a social media adviser or the social media team finds a violation of law (e.g.: HIPAA or FERPA) or a violation of UF or UF Health policy, they will contact the unit’s social media account managers and chief faculty member describing the violation and requesting that it be removed immediately. Advisers should also contact the UF Health social team so they are aware of the incident.
    • Known or suspected privacy violations must be reported to the appropriate Privacy Office. The UF Health social media team also reports these incidents to the Chief Communications Officer, the Director of External Communications, and the Public Relations Specialist.
    • Other, less serious issues can be addressed in meetings or through informal communications.

Monitoring social media accounts and addressing risk

  • Social media managers will be responsible for monitoring their channels during and after business hours (push notifications from social media accounts must be enabled for account managers).  
  • When possible, privacy settings should be set so that users may not upload their own photos or videos to the sites.
  • Patient Privacy: Use of social media, even in a personal capacity, must comply with the Health Insurance Portability and Accountability Act (HIPAA). For a general overview of HIPAA, please visit: https://privacy.ufl.edu/uf-health-privacy/
    • Unless a patient has completed a media release form, do not post patient information, even if you think you have “de-identified” it.
      • It often is possible to identify patients even if you do not include their names or other obvious identifying information.
      • Realize that details, such as your name, your place of work/study and the date/time stamp can make it easy to identify patients you describe, particularly to the patients themselves and their families and friends.
      • The most important aspects of monitoring comments are keeping protected health information (PHI) limited.
      • Protected health information includes photographs and videos of the patient, even if the patient asked for the photo/video to be made or consented to it being made. It is best to return such photos to the patient, as long as no other patients are in the photos. A media release form from UF Health Communications must be completed prior to sharing any photos or videos, including with a patient.
    • Posting one’s own PHI – If an individual identifies himself or herself as a patient and then voluntarily shares his or her own PHI with the audience via a comment, we may allow the comment to remain on the site. 
    • Posting of another’s PHI – Comments, photos, videos or any other type of content containing PHI pertaining to another person (e.g., comments about a friend or neighbor), must be deleted immediately by the page administrator or their designee when discovered. See exception pertaining to parents/legal guardians commenting about their own children below.
      • Before deleting content, please take a screenshot and send the image to UF Health Communications, along with a note of when the content was deleted and why.
      • Exception: UF Health social media sites may allow parents of minors to post comments containing the PHI about that parent’s own child when there is a clear admission that the “poster” is that parent of the minor. Such comments, although permissible, may be removed per additional removal criteria listed below.
      • Posting of Super-Confidential Health Information – Comments containing super-confidential health information, regardless of who posts the information, must be deleted immediately when discovered. Super-confidential health information: Certain health information incurs an additional layer of confidentiality. This includes information pertaining to diagnosis, treatment and/or examination related to Mental Health; Substance Abuse (including drugs or alcohol); HIV/AIDS (and testing of); Sexually Transmitted Diseases, and Genetic Information as defined and protected by specific federal/state laws and regulations.
    • Humanitarian/Overseas Trips: Patients treated on international humanitarian trips have a right to privacy, even if they were treated outside of the U.S. Treat these patients’ identities and medical information, as well as photos, videos and audio recordings featuring them, with the same respect you would show those of a patient receiving care in the United States. Disclosing information about a patient treated in another country could be a violation of that country’s privacy laws, as well as U.S. and Florida laws and UF and UF Health Shands policies. See also: the UF Social Media Use, Guidelines and Policy Implications document on the UF HR website (http://www.hr.ufl.edu/emp_relations/policy/social_media.asp https://hr.ufl.edu/forms-policies/policies-managers/social/) and UF Health Shands Social Media Policy (HR#322). Before you post information, pictures/videos, recordings featuring patients from an international humanitarian trip, please contact the appropriate Privacy Office for approval. Official UF visits to other countries may invoke national privacy protections different than those in the United States. When data are collected and exported, for example individually identifiable photographs, the national laws of the country visited must be followed.
    • Confidentiality of student and applicant records: Federal laws (including the Federal Education Records and Privacy Act, or FERPA), Florida law and UF regulations governing the confidentiality of student (education) and applicant records (and information from such records) apply to social media use. Information from student, alumni or applicant records (including but not limited to academic records, disciplinary records, correspondence through e-mail or other means, or any other records concerning students at the University of Florida or applicants to the university) should never be released via social media. For more information about the privacy of student and applicant information, please view the following resources:
    • Research and intellectual property: Releasing unpublished research data or unprotected intellectual property would impair its protection. In keeping with UF’s Intellectual Property Policy ( https://generalcounsel.ufl.edu/media/generalcounselufledu/documents/Intellectual-Property-Policy.pdf) and UF Health Shands Intellectual Property policy (HR 313), you may not release unpublished research data or unprotected intellectual property through social media.
    • Other forms of restricted information: Revealing other forms of restricted records, data or information via social media is strictly prohibited. Records so protected include but are not limited to Social Security numbers, financial information, employee medical information, limited access employee records pursuant to Section 1012.61, Fla. Stat., trade secrets, copyrighted materials, and other materials that the university has agreed shall be maintained confidentially.
    • Misrepresentation: You may not portray yourself as acting on behalf of the university or any part of the university, such as the academic health center, IFAS, a college, department or any other unit, or present a social media account as an official university account unless authorized to do so. When using social media in a personal capacity, you must take reasonable precautions to indicate that you are engaging in the activity as a private person and not as an employee, agent or spokesperson of the university. Permission to use any University of Florida service marks, trademarks or logos must be requested from University Strategic Communications and Marketing.
    • Inappropriate comments: All content is bound by the UF Acceptable Use Policy. Further, users are expected to abide by applicable laws, regulations, rules and policies including the University Student Code of conduct, the University’s Sexual Harassment Policy and other regulations and policies concerning public communications.
      • When discovered, a unit social media manager must immediately remove inappropriate comments about the organization or a staff member that are offensive, abusive and/or insulting. UF Health social media sites may allow negative comments relating to quality of care that do not meet the removal criteria above, unless such comment contains PHI pertaining to another person or is super-confidential in nature.
      • Further in this document we share instructions about how to respond to such comments.
      • Accounts run by UF units are subject to public records laws and freedom of speech considerations. For these reasons, comments and other content added by users other than the social media managers should be removed from the social media pages only when there is a very compelling reason to do so. Content should not be removed solely because the managers or other unit personnel dislike it, or solely because it puts UF Health in a negative light. Prior to deleting or hiding a comment, please contact the UF Health social media team to make them aware of the situation.
    • If an individual offers a comment that would serve as a follow-up marketing or public relations patient testimonial or newsworthy story, the UF Health Communications team will contact the individual to secure an Authorization to Use or Disclose Patient Information for Communications Media form. This consent form will cover not only distributing the message through social media sites but also using it in other UF Health marketing, promotion and news efforts.
    • Responding to comments: Responding to a patient who greets you on a social media platform is OK. Providing medical advice or information is not, even if the patient requests it. Not all comments will require a response; some comments may be simple statements or praise, or tips for other UF Health or UF customers. 
      • When responding, staff shall remove any PHI contained in the original message. See also CP3.36 Deidentification of Patient Information for additional information.
      • If the comment requires a more in-depth answer, AND is not a complaint per CP1.16 Patient and Family Complaints and Grievances, our response should promise an answer within a set amount of time (preferably 48-72 hours, or two to three business days). Due to the nature of this type of marketing, the response shouldn’t have a “corporate” tone. An example of this response, which should be posted to the site for the world to see, would be: Thank you for contacting UF Health. Due to the nature of this issue, we will need some time to respond. Please be patient. We will respond to you within three business days.
      • If the message requires an in-depth response, AND is not a complaint, and the content is outside the scope of the site administrator or department hosting the site, then the site administrator must work with the appropriate department liaison(s) to craft a response. If a site administrator is unsure of who to contact to address a comment, he or she may contact a UF Health Communications member for assistance.
      • If a comment involves a complaint/grievance*, the standard response should not be handled privately and should say something like: Thank you for contacting us UF Health. We appreciate your feedback and your concerns are important to us. In order for us to follow-up with you appropriately, please contact a patient representative at 352-265-0123 with issues and or concerns.
        • The definition of a patient complaint/grievance, as per Shands Core Policy CP1.16 is as follows: Patient Grievance – a formal or informal, written or verbal complaint that is made to the hospital by a patient, or the patient’s representative, regarding the patient’s care, abuse or neglect, issues related to the hospital’s compliance with the CMS Hospital Conditions of Participation, or a Medicare beneficiary billing complaint related to rights and limitations provided by regulation or a complaint alleging violation of patient confidentiality.
        • IMPORTANT: Comments that are complaints or grievances must be sent immediately when discovered to the UF Health social media team, who will send to the designated facility’s complaint-management representative and other UF Health senior leadership, who will then determine the applicability of CP1.16, Patient and Family Complaints and Grievances. These individuals will work with UF Health communications staff to develop an appropriate response to the comment(s). Typically these responses will be handled privately, but we may decide that our response will shed light on a particular concern or issue and how UF Health is managing that issue, and thus the response will be appropriate on the social media platform. It is also important to note that UF Health staff must adhere to Core Policy 3.14 Email and Calendar Use when transmitting electronic messages to patients or other individuals. CP3.14 prohibits the sending of emails which contain PHI to external email addresses (i.e. those ending in yahoo.com, hotmail.com, etc.) unless that email transmission is encrypted.
        • IMPORTANT: All comments that are deleted should be saved in a Word document and submitted to the UF Health social media team for record-keeping, in compliance with the Florida public records law. A screenshot of the comment is an acceptable means for documenting a removed message.
      • “Facebook terms and conditions” to be posted on each Facebook Page: The Facebook terms and conditions document in Appendix A to these guidelines must be customized appropriately (see [brackets] for customizable areas) and posted on a tab on each UF Health-approved Facebook account.
      • Additional information about blogs: Blogs started by employees and hosted on other domains are considered personal blogs. These blogs must not be advertised or run as official UF or UF Health blogs. If such a blog contains discussion of health-related issues or work matters, the employee should post a disclaimer stating that the blog is not an official UF or UF Health blog, and that the opinions expressed there are his or her own personal opinions and not those of UF or UF. Employees who discuss work matters on personal blogs should be well- versed in appropriate social media behavior and should not violate privacy or other laws that relate to their work environments.
    • Training: Social media advisers and unit social media managers will be required to attend initial training on social media management, strategies, policies and guidelines. Subsequent training sessions may be offered as new information becomes available and may be mandatory or optional. Social media monitors and unit social media managers should proactively pursue updates, which may come from the web services team, the UF Health Communications social media team, UF Health Communications,  or University Relations. 

References

Facebook About Us Content – recommended additions by UF Health Legal and Privacy 

This Facebook page was created and is managed by [department name].

The purpose of this page is to share the research, clinical and academic work that takes place at UF Health, the University of Florida academic health center. Content posted on this page should be in keeping with this purpose. Content should not reveal another person’s protected health information, student records information, or any other information protected by existing privacy laws. Any such materials/comments will be removed.

Comments left on this page do not reflect in any way the opinions or policies of UF or any of its colleges or departments or UF Health. Further, UF Health disclaims any liability whatsoever for any postings or other material which are or may become a part of this Facebook page and does not warrant or guarantee that the postings or other materials will not be offensive to a user of the page. UF Health does not prescreen comments.

At the same time, UF Health, UF and UF Health Shands reserves the right to block the content of any post that violates any UF or UF Health policy, rule or regulation or applicable law. UF Health has the right to remove content from this Facebook page at any time, without prior notice, whenever it is deemed to be in UF Health’s best interest to do so. Please be aware that all content and posts are bound by the following:  Facebook’s Terms of Use and Code of Conduct;  UF’s policies, rules and regulations, including without limitation; UF’s Acceptable Use of Computing Resources Policy and other applicable law, including without limitation copyright law.
Florida has a very broad public records law. As a result, comments received are public records subject to disclosure to the public upon request unless otherwise exempt. Any materials / comments posted here will be retained for a period of time, even if they are deleted from the page.

If you encounter abusive content, please report to Facebook and to the page’s administrators. To report violations of a UF or UF Health policy, rule or regulation, please refer to the policy, rule or regulation in question for reporting / contact information.

If you have a concern about content posted by the administrators of this [department name] Facebook page, please e-mail us at [contact email].