Public Notices: Social Media Guidelines for Employees

Social media has become an increasingly popular — and a very useful — part of the Internet. Social media includes multiple media for sharing information including, but not limited to, blogs, networking sites, virtual worlds, and video- and photo-sharing sites. Memorial Sloan Kettering Cancer Center also is now using some of these tools, including Facebook, Twitter, YouTube, and blogs, to build an online community and communicate with our patients and other members of the public. We’re eager for you to be part of the conversation as well.

However, MSKCC’s reputation online is important and we rely on you to follow these simple but important guidelines.

Follow some basic, common-sense principles. Always remember that the same rules that apply to any other form of communication apply when you are using social media. This means that all online communication by MSKCC employees or their representatives and/or vendors is subject to MSKCC’s Code of Conduct, Policy on Electronic Communications, Information Systems Handbook, and media procedures, as well as HIPAA regulations and all other relevant policies, laws, and regulations, including federal copyright laws. Unless specifically authorized by the Department of Public Affairs, no MSKCC employee is authorized to make a posting to any website on behalf of MSKCC, and MSKCC shall not be liable for such unauthorized acts.

Be transparent. If you are communicating by social media or with bloggers and endorsing MSKCC or any of its activities in an advertisement, testimonial, or similar context, you must disclose your affiliation with MSKCC, even if this communication is not part of your official work responsibilities. MSKCC “activities” include, but are not limited to, patient care, biomedical and related research, clinical trials, drug development, and education and training programs. When communicating in these situations, you should make it clear that you are speaking for yourself, and not on behalf of MSKCC. And if you substantively comment or post on MSKCC’s Facebook page (beyond just “liking” an item on the page), you must identify yourself as an employee in the content of your comment or post if you are not already so identified in your public profile.

Here is some language you should use. “I work for Memorial Sloan Kettering Cancer Center, but this is my personal opinion and may not reflect the views of my employer.”

Be yourself. Never use a pseudonym or “anonymous” identifier when commenting on issues related to activities on MSKCC’s Facebook page or other MSKCC-sponsored social media.

Maintain confidentiality. Make sure that you do not disclose any confidential or proprietary information about MSKCC’s activities, including but not limited to intellectual property or trademarked information or information related to our patients, including but not limited to protected health information (PHI) subject to HIPAA.

We believe in free but respectful speech. The posting of harassing, discriminatory, and/or defamatory material in violation of MSKCC’s policies against harassment, discrimination, and retaliation may result in disciplinary action up to and including termination of employment.

Separate the personal from the professional. Use a personal e-mail address as your primary means of identification. Just as you would not use MSKCC stationery to express personal views in a letter to the editor, do not use your MSKCC e-mail address when expressing your views and opinions online. Physician/patient online interactions are subject to the same professional boundaries as they are in any other physician/patient setting, and MSKCC employees are discouraged from “friending” patients unless the relationship existed prior to the individual being treated at MSKCC. MSKCC physicians should exercise caution when posting comments online that may be considered providing medical care and know that such comments could be subject to liability. Additionally, superiors are discouraged from “friending” employees unless the employee initiates the interaction, and employees should not feel obligated to accept such requests from their superiors as part of their employment.

Our name and logos belong to the organization. Therefore, do not use Memorial Sloan Kettering’s name, the official logos of Memorial Sloan Kettering Cancer Center, the Sloan Kettering Institute, or the Gerstner Sloan Kettering Graduate School of Biomedical Sciences, or any related marks or images to promote or endorse any product, cause, political party, or candidate.

Sharing MSKCC information? First make sure it’s OK to share it with the public. If you have a blog or other social media account, you may wish to share MSKCC information relating to its activities. That’s fine, and we encourage you to let people know about what is going on at MSKCC. But first make sure that it has already been made public by MSKCC. If you have any questions about whether certain information has been released to the public, contact Public Affairs.

We need to see your department’s MSKCC-related videos before you post them. The Department of Public Affairs has the sole and exclusive right to approve and coordinate the posting of MSKCC-related videos (on sites like YouTube and Vimeo) and MSKCC-related photography (on sites like Flickr). If your department would like to post such materials on these or other third-party websites, please contact Public Affairs.

We also need to see your department’s Facebook (or other) group before it goes live. If your department wants to create a Facebook group or set up another social media page or site, you first need to get the approval of your manager. Then you should contact Public Affairs. Although you work at MSKCC and your group may look official, this doesn’t mean that it is. We have to make certain that what you propose to do does not confuse members of the public who may visit your group, page, or site, and must ensure that it is branded appropriately.

Work and social media don’t mix. Please exercise good judgment and don’t allow blogging and social networking to interfere with your job responsibilities. We want you to start conversations in the social media space that can contribute positively to the public’s understanding of our goals and mission — but your work at MSKCC comes first.

The Internet is not private — and it’s forever. So remember that patients, colleagues, and supervisors may have access to the online content you post — and it will never go away. Keep this in mind when publishing information and know that something originally intended just for friends and family can be forwarded to others. There is no such thing as a “private” social media site. Search engines can turn up posts many years after the publication date, comments can be forwarded or copied, and archival systems save posts even after you believe you have deleted them.

If in doubt, leave it out. A good rule of thumb is if you would not want your manager, other colleagues at MSKCC, or another potential employer to see your comments, you should not post them on the Internet.

Help us help you. If you would like to use social media in your department, first clear it with your supervisor and then get in touch with Public Affairs (publicaffairs@mskcc.org). They can help you get started. This will also ensure that MSKCC’s various social media initiatives are coordinated effectively. Additionally, if you notice persistent online commentary from other employees that is inconsistent with these guidelines, please bring it to the attention of your supervisor or Public Affairs.

If you have any questions about what is appropriate to include in your blog, Facebook page, Twitter feed, or YouTube channel, or if you have questions about any other social media-related issues, please contact Public Affairs at publicaffairs@mskcc.org.