Social Media Guidelines
Faculty, students and staff are charged with unique roles in the areas of patient care and the advancement of medicine. Due to these unique responsibilities, these guidelines seek to serve as an addendum to the Washington University in St. Louis (University) social media policies (issued 12/09) and provide further guidance in areas unique to the Washington University School of Medicine’s (WUSM) mission.
These guidelines apply to:
- Any university business or the representation of WUSM and Washington University Physicians in or on any social media venues, including those co-sponsored by affiliated institutions where WUSM faculty and staff work. These institutions include but are not limited to BJC HealthCare, Shriners Hospital for Children, the VA Medical Center, Central Institute for the Deaf, and the Rehabilitation Institute of St. Louis.
- Faculty and staff members that identify themselves with WUSM and/or use their WUSTL email address in social media venues for deliberate professional engagement or casual conversation.
All faculty, students and staff of WUSM are asked to be mindful of their roles in protecting patient confidentiality at all times, including during participation in social media venues.
We expect all who participate in social media on behalf of WUSM to understand and follow these guidelines and the University’s Social Media Policies.
Social media platforms are among the current and new technologies that will continue to emerge. These policies and guidelines apply, but are not limited, to sites such as YouTube, Vimeo, Facebook, iTunes, blogs, web feeds such as RSS, Twitter, MySpace, LinkedIn, Flickr, community forums and chat rooms, list serves, social bookmarking sites and other forums.
The Office of Medical Public Affairs oversees the WUSM’s official presence on social media sites and works in conjunction with the University’s Office of Digital Communications Marketing to develop, review, approve, monitor, amend, and when necessary, remove WUSM social media pages or sites.
WUSM representation on online social media platforms can only be initiated through and authorized by the Office of Medical Public Affairs.
Social media platforms such as Facebook, YouTube, Flickr, Twitter and many others offer unique opportunities to connect and communicate with people across the globe.
Washington University School of Medicine supports the use of social media initiatives that seek to share and support its educational, research and clinical missions. Members of the WUSM community are asked to be professional, confidential and technically secure, and transparent of their identity in all communications on behalf of the School of Medicine and University.
Take a moment to consider the following elements of any effective, strategic communication before you begin:
||Whom are you trying to reach?Applicants, patients, alumni, or another group?
||What would you like your audience to do with you on social media?Chat and share, learn about events, get news?
||How often will you communicate with your audience?
|Choice of Platform
||Questions to consider include: Can you use Twitter to connect with thought leaders or send brief, timely updates? Or would you like to build a following of friends on Facebook?
Do you have videos to post on YouTube? Or lots of high-resolution images to share on Flickr?
||Understand the security limitations of social media sites.
- Contact the Office of Medical Public Affairs prior to launching any social media initiatives. Representation of WUSM on online social media platforms must be approved by and coordinated in conjunction with the Office of Medical Public Affairs.
- Authorization must be obtained first from the Office of Medical Public Affairs, before using the University’s or WUSM’s names and logos, including the names of departments, programs and divisions and clinical endeavors. All policies, procedures, and guidelines regarding University trademarks, names, and symbols apply to social networking sites. Existing social media activities must be reviewed and approved or amended as necessary.
- Participation in or on social media platforms can be created by, assigned to and maintained by representatives of departments, divisions, programs or their delegates under the guidance of the Office of Medical Public Affairs.
- All social media participation must assign a primary site administrator responsible for content and adhere to applicable policies and procedures. The primary administrator should be an employee of the University. If not an employee of the University, the primary site administrator must be directly supervised by an employee of Washington University who assumes responsibility for the primary site administrator’s work. The site administrator’s name and title, as well as all parties with administrative access to the site, shall be forwarded to the Office of Medical Public Affairs, posted on the site, and kept current by the department, division or program responsible for the social media forum. The Office of Medical Public Affairs can approve requests for assistance or shared site administration by other parties (See Shared Administrative Access to Social Media Platforms, page 3).
- The primary site administrator will ensure that:
- Content is appropriate, accurate and timely.
- Content complies with all privacy, corporate compliance, copyright, disclosure, conflict of interest, HIPAA and other relevant laws and University and WUSM’s policies.
- Site or page complies with the naming conventions for social media initiatives at the School of Medicine. (See table below)
- Appropriate consent is obtained and documented for content including words, graphics, photos, video, audio, images, PowerPoint presentations, artwork, and any other included elements.
- Content does not constitute advertising. The University does not endorse commercial enterprises, including in its digital communication unless approved by the Office of Public Affairs. Promotion of an event sponsored by the University or its hospital partners is acceptable.
- Content is monitored daily, or more frequently if necessary, and postings and comments adhere to policies.
- All blog or comments posted by members of the WUSM community on behalf of WUSM patient care and business operations on WUSM online forums must be written by WUSM faculty, or staff or students under the direction of a faculty member, and must not be written anonymously or by third-party entities.
- All errors are immediately corrected and corrections notes with the original post.
- Offered links are reviewed and deemed appropriate.
- Text links to the approved HIPAA Notice of Privacy and WUSM Disclaimer regarding digital communications are displayed on the main page of all social media sites or pages related to WUSM.
- In instances in which a potential conflict of interest could exist, a link to the WUSM page on disclosure, containing appropriate language pertaining to potential research or clinical conflicts of interest is displayed on the main page of all social media sites or pages. Information on clinical conflicts of interest is available on the Washington University Physicians website, while research-oriented information may be accessed on the website for the Office of the Vice Chancellor for Research.
- Washington U Medicine, a Facebook account managed by the Office of Medical Public Affairs, should be invited to be a member of your group. Once accepted, the primary site administrator should make Washington U Medicine an administrator of the group. The Washington U Medicine profile will not make any changes/decisions about your group; their involvement is only to provide support in crisis situations.
- Comments on official WUSM forums that contain any of the following are subject to editing, rejection or deletion:
- Reference to first/last names, identifying locations or other personal or patient information
- Profanity, racist, sexist, discriminatory or other derogatory content
- Plagiarism or infringement upon or violation of the rights of third parties, such as copyright, trademark, trade secret, confidentiality, intellectual property or patent
- False claims, including those not in compliance with AMA guidelines
- Spam, spyware, virus or other component or computer code or script that is or could be harmful
WUSM recognizes that responsibility for some social media initiatives may be shared among affiliated institutions/hospital partners such as Barnes-Jewish Hospital, St. Louis Children’s Hospital, Barnes-Jewish West County Hospital, Shriner’s Hospital for Children in St. Louis and their employees. In such instances, the social media policies and guidelines of all participating institutions apply.
The site administrator will provide the names, titles and contact information for any individuals who share administrative access to a given social media page or site to the Office of Medical Public Affairs. Sharing primary site administrative responsibilities with individual patients, families, donors or students is generally not recommended.
Patient privacy is of utmost importance. The site administrator and all participants representing WUSM must follow all existing WUSM policies and guidelines including HIPAA, Release of Information, Conflict of Interest, Intellectual Property, the site’s User Terms and Conditions and routine approvals through the appropriate department, division or program.
Social media sites like Facebook, Twitter, Doximity and others are considered open systems and may not be used to receive, discuss or transmit electronic patient identifiable health information.
Sending email messages to outside mailboxes and systems (e.g. Facebook, Yahoo, Gmail) is considered unprotected. The only approved methods for sending patient information via the Internet are: 1) Use of an encryption method to render the patient information unreadable while in transit or 2) Written consent in which a patient agrees to transmission of patient information via email.
If these methods are not followed, any emails or communications sent across the public Internet would constitute a breach of patient privacy.
Use of social media platforms for clinical trial recruitment must be reviewed by the WUSM Institutional Review Board (IRB). Proposals for use of social media platforms for this purpose should be submitted to the WUSM IRB by the principal investigator during the normal protocol submission process.
The University does not permit explicit or implied use of the University’s or School of Medicine’s names, trademarks, logos or images – including pictures of campus buildings – to endorse any product or service without approval by the Office of Public Affairs or Medical Public Affairs.
All official social media initiatives related to clinical or health care topics, clinical study recruitment, and/or involving representatives from the clinical practices of WUSM shall include in-line text links to the Conflict of Interest in Clinical Care – Policy and Consulting Agreements Guidelines.
Many partners at the School of Medicine will benefit from creating a Facebook group rather than a Facebook page.
Management of any Facebook group will be the responsibility of the department/division/office choosing to create the group. Before creating a group, there must be a firm commitment to be involved in the group on a daily basis to monitor activity and interact with group members as appropriate. All WUSM and BJC social media policies apply to Facebook.
To set up a Facebook Group:
- Go to the Facebook website from a desktop computer (e.g., not a from a mobile app). Using your personal Facebook profile, click Create Group in the left column to set up a new Facebook group. You may customize the group in any way using the options and settings provided by Facebook.
- Invite the “Washington University School of Medicine” profile to be a member of your group (WUSM Medical Public Affairs team manages this profile). Once accepted, make Washington University School of Medicine an administrator of the group. The Washington University School of Medicine profile will not make any changes/decisions about your group.
- If your page or site offers communications about Washington University clinical services, Washington University should be part of your group’s name and mentioned, along with the appropriate hospital in your group’s description. The appropriate co-branded logo should be a part of your group’s visual identity. A WUSM, Physicians or co-branded logo can be provided upon request. Please contact a representative from Medical Public Affairs or the Faculty Practice Plan’s Communications Office.
- A link to the WUSM disclaimer regarding digital communications must be added to the group description, along with links to the HIPAA Patient Privacy and Conflict of Interest policies.
- All HIPAA regulations apply to Facebook Groups. Do not discuss PHI about any patient at any time. A member of the group may volunteer PHI, but you may not address the PHI publicly – use a private/off-line message to encourage the member to contact your office of business to discuss when applicable. Always use good judgment about content and be careful not to include confidential information.
- Do not post anything to Facebook that you do not want others to see. While your group will most likely become an informal space, staff members should treat all interactions in the Facebook group professionally.
- You may post photographs of patients to the site only if you have a signed consent (for an adult patient) or parent’s/guardian’s consent (for a pediatric patient). Consents for both WUSM and a hospital partner should be obtained as appropriate.
- You may not tag any patients in photographs, and you may only refer to patients by first name when populating a photo description.
- If someone ever posts something in your group that is profane, abusive, threatening or questionable in any way, do not respond or delete anything. Immediately contact the primary administrator of your site/page or a representative from Medical Public Affairs or the Faculty Practice Plan Communications Office. Using standard crisis communications protocols, the team will quickly determine the appropriate way to act/respond.
Personal self-hosted social media sites unrelated to WUSM business or activities must clearly and prominently state that they do no represent the opinions or views of WUSM or the University and that they convey the personal views of the creator.
The University does not monitor these personal pages and is not responsible for their content. Such personal content, if using the wustl.edu domain, must comply with local, state and federal law — and must not involve copyright infringement, constitute libel or harassment, contain illegal materials, or consume inappropriate amounts of bandwidth.
The University’s Computer Use Policy provides further guidelines for appropriate use by students, faculty and staff of computer facilities and services
Activities that do not identify a faculty or staff member with WUSM, do not use a WUSM email address, do not discuss WUSM or its patients and solely concern personal matters would normally fall outside these guidelines.
- Follow all existing WUSM policies and guidelines, including HIPAA, Conflict of Interest Policy, Intellectual Property and general civil behavior guidelines cited above.
- Respect copyrights, trademarks and intellectual property of the University, WUSM and others.
- Protect others’ privacy and their proprietary financial, patient care or similar sensitive or private content.
- Be professional and respectful in all postings. Be mindful that all communications in the online environment are visible to patients, co-workers, managers, competitors and others. Remember that nearly all content contributed on all social media platforms becomes immediately searchable and can be immediately shared.
- When representing WUSM or WUSTL, identify yourself and your role with the organization in all posts. Use good judgment and strive for accuracy. Errors and omissions could result in liability for you or for WUSM.
- When you are expressing personal views, and when your association with WUSM is shared, implied or apparent, make it clear that your opinions are personal and do not represent the views or opinion of WUSM/WUSTL. Washington University is committed to a work environment free of harassment and disruptive behavior, and to providing an equal opportunity work environment where every member of the University community is treated with fairness, dignity and respect. No one shall discriminate against any individual on the grounds of race, color, religion, sex, age, disability, sexual orientation, national origin, or any other factor prohibited by law.
- Your personal online social networking activities should be kept separate from your professional online activities to help maintain appropriate boundaries when interacting with patients online and to ensure patient privacy and confidentiality. Use privacy settings to safeguard personal information on non-work related activities as appropriate. The practice of accepting patients as friends on personal, non-WUSM or WUSTL accounts should be thoughtfully considered. Many professional societies and associations already have guidelines in place concerning this policy. Monitor your Internet presence to ensure accuracy and appropriateness of content posted about you. (Adapted from the AMA Ethical Guidelines for Social Media.)
- Be thoughtful about how you present yourself as a WUSM faculty or staff member in online networks. By virtue of identifying yourself as part of WUSM in such a network, you are now connecting yourself to your colleagues, managers and even WUSM patients and donors.
- Always adhere to the site’s user terms and conditions.
- Make sure your online activities do not interfere with the completion of your job responsibilities.
- If someone or some group offers to pay you for participating in an online forum in your WUSM role, this could constitute conflict of interest and WUSM policies and guidelines apply.
- If someone from the media or press contacts you about posts you have made in online forums that relate to WUSM in any way, you must alert your manager and contact the Office of Medical Public Affairs before responding. Medical Public Affairs will provide assistance, including preparation of official information that can be appended to the social media site, and work with you to resolve the situation.
- If you wish to write about other Universities or healthcare providers, information should be respectful and factually accurate.
- Never comment on anything related to legal matters or litigation involving WUSM. Contact the Office of Medical Public Affairs if you require further assistance.
- In order to provide the utmost care for our patients, employees and students, and the community at large, refer all social media activity around crisis topics to the Office of Medical Public Affairs. Never comment on social media sites on topics related to crisis situations involving WUSM, the University or its affiliated institutions. Be mindful that anonymous comments may be traced to any WUSM or BJC IP address.
- When identifying yourself and your role with the WUSM in a personal online forum, use good judgment and strive for accuracy. Errors and omissions could result in personal liability.