SOCIAL MEDIA & CONFIDENTIALITY POLICY

INTRODUCTION 

This policy sets out Prison Network (PN) staff and volunteer obligations in relation to their use of social media and the confidentiality of information obtained through their work regarding the prison, prison system, the women and their families. 

Social Media 

Social media such as Twitter, Facebook, Google+, YouTube and blogging represent a growing form of communication for not-for-profit organisations, allowing them to engage their members and the wider public more easily than ever before. 

This policy is aimed at maximizing PN’s social media reach while protecting its public reputation. Unless formally advised by the CEO, a staff member or volunteer generally will not be authorized to comment as a representative of PN or on behalf of PN. 

Confidential Information 

PN staff and volunteers operate in a regulated and structured environment, where information about prison procedures and processes and information about prisoners and their families is highly confidential. Any information about offending or ex-offending women or their families obtained either verbally or in writing by PN staff or volunteers in the course of PN work is confidential and may ONLY be disclosed to PN staff members or volunteers, where this is required for PN to undertake its responsibilities. 

SOCIAL MEDIA POLICY 

PURPOSE 

PN may choose to engage in social media such as: 

  • Twitter 

  • Facebook 

  • Google+ 

  • WordPress/Blogger 

  • YouTube/Vimeo 

  • iTunes/Podcasting 

PN also uses a website to publish information about its activities, its services and its staff and volunteers. 

PN wishes to encourage information and link-sharing amongst its staff, volunteers and those external to PN and seeks to utilise the expertise of its employees and volunteers in generating appropriate social media content. PN seeks to grow its social media base and use this to engage with existing and potential members, donors and stakeholders. 

At the same time, social media posts should be in keeping with the image that PN wishes to present to the public, and posts made through its social media channels should not damage the 

organisation’s reputation in any way. Therefore, staff and volunteers must be familiar with this policy. 

CORE POLICY 

PN’s social media use shall be consistent with the following core values: 

Integrity: PN staff or volunteers will not knowingly post incorrect, defamatory or misleading information about its own work, the work of other organisations, or individuals. In addition, prior to posts or information being made publicly available, PN staff and volunteers will ensure that any copyright or privacy laws applying to the information, are complied with. 

Professionalism: PN’s social media represents the organisation and should maintain a professional and uniform tone. Staff and volunteers may, from time to time post on behalf of PN using its online profiles, but the impression should remain one of a singular organisation rather than a group of individuals. 

Information Sharing: PN encourages the sharing and reposting of online information that is relevant, appropriate to its aims, and of interest to its members. 

If a staff member or volunteer is in any doubt about the posts that are to be made, they should consult with the CEO or a senior support worker. 

POSTING 

Before social media posts are made, volunteers and staff should ask themselves the following questions: 

  • Is the information I am posting, or reposting, likely to be of interest to PN’s members and stakeholders? 

  • Is the information in keeping with the interests of the organisation and its aims? 

  • Could the post be construed as an attack on another individual, organisation or project? 

  • Would PN’s donors be happy to read the post? 

  • If there is a link attached to the post, does the link work, and have I read the information it links to and judged it to be an appropriate source? 

  • If reposting information, is the original poster an individual or organisation that PN would be happy to associate itself with? 

  • Are the tone and the content of the post in keeping with other posts made by PN? Does it maintain the organisation’s overall tone? 

Staff members or volunteers MUST NOT: 

  • Post comments that indicate you have been at the prison or comment on other people’s social media posts. This includes posting comments on issues that have had significant media coverage. 

  • Take any photographs of the prison compound (even from the street). 

  • Have contact with offenders or ex-offenders via social networking sites (eg: Facebook, Instagram, Twitter), except with the consent of the CEO or a senior support worker. 

When Posting on behalf of PN: 

If a staff member or volunteer is authorized to disclose information on behalf of PN, the following rules apply: 

  • only post information already in the public domain, and ensure that any information published is not confidential or subject to privacy or copyright restrictions; 

  • do not post material that is offensive, obscene, defamatory, threatening, harassing, bullying, discriminatory, hateful, racist, sexist, infringes copyright, constitutes a contempt of court, breaches a court suppression order or is otherwise unlawful; 

  • ensure that all content published is accurate and not misleading; 

  • comment only on your area of expertise and authority; 

  • be polite and respectful to all people you interact with; 

  • ensure comments are respectful of the community in which you are interacting online; 

  • do not make any comment or post any material that might otherwise cause damage to PN’s reputation or bring it into disrepute. 

When making Private Posts: 

Individuals are free to use social media forums, but in doing so, staff and volunteers should recognise the potential for damage to be caused (either directly or indirectly) to PN in certain circumstances through the personal use of social media when a staff member or volunteer can be identified as a PN employee or staff member. 

Accordingly, you should comply with this policy to ensure that the risk of such damage is minimised 

Where your comments or profile can identify you as a PN staff member or volunteer, you must: 

  • only disclose and discuss publicly available information; 

  • only post information already in the public domain, and ensure that any information published is not confidential or subject to privacy restrictions; 

  • be polite and respectful to all people you interact with. 

You must not: 

  • post material that is offensive, obscene, defamatory, threatening, harassing, bullying, discriminatory, hateful, racist, sexist, infringes copyright, constitutes a contempt of court, breaches a court suppression order or is otherwise unlawful; 

  • imply that you are authorised to speak as a representative of PN, nor give the impression that the views you express are those of PN; 

  • use or disclose any confidential or personal information obtained in your capacity as a staff member or volunteer of PN; 

  • imply you are authorised to speak on behalf PN, or give the impression that any views you express are those of PN; 

  • post material that is, or might be construed as, threatening, harassing, bullying or discriminatory towards another staff member or volunteer of PN; 

  • make any comment or post any material that might otherwise cause damage to PN’s reputation or bring it into disrepute. 

Damage limitation 

In the event of a damaging or misleading post being made, the CEO should be notified as soon as possible, and the following actions should occur: 

  • The offending post should be removed. 

  • Where necessary an apology should be issued, either publicly or to the individual or organisation involved. 

  • The origin of the offending post should be explored and steps taken to prevent a similar incident occurring in the future. 

  • The CEO will liaise with the Board on any further actions that may be required. 

Moderating social media 

The reputation of PN is first and foremost. From time to time social media forums may be hijacked by trolls or spammers, or attract people who attack other posters or the organisation aggressively. In order to maintain a pleasant environment for everybody, these posts need to be moderated. 

Freedom of speech is to be encouraged, but if posts contain one or more of the following, it is time to act: 

  • Excessive or inappropriate use of swearing; 

  • Defamatory, slanderous or aggressive attacks on PN other individuals, organisations, projects or public figures; 

  • A breach(s) of copyrighted material not within reasonable use or in the public domain; 

  • Breach(s) of data protection or privacy laws; 

  • Repetitive advertisements; 

  • Topics which fall outside the areas of interest to members and stakeholders, and which do not appear to be within the context of a legitimate PN discussion or enquiry. 

If a post appears only once: 

  • Remove the post as soon as possible; 

  • If possible/appropriate, contact the poster privately to explain why you have removed the post and highlighting PN’s posting guidelines. 

If a poster continues to post inappropriate content, or if the post can be considered spam: 

  • Remove the post as soon as possible 

  • Ban or block the poster to prevent them from posting again. 

Banning and blocking should be used as a last resort only, and only when it is clear that the poster intends to continue to contribute inappropriate content. However, if that is the case, action must be taken swiftly to maintain the welfare of other social media users. 

The decision to block, ban and remove posts ultimately lies with the Board, but may, at its discretion, be delegated to responsible staff. 

CONFIDENTIALITY POLICY 

PN generally does not collect or hold personal, sensitive or health information in the work it undertakes with offending women or ex-offending women and their families. There are certain specific circumstances where it does collect and store information, set out below. 

However, in the close and personal work it undertakes with the women and their families, PN staff and volunteers will come into knowledge of a range of personal issues faced by the women and their families, that would, if written down and stored by PN, be likely to come under the Information Privacy and Security laws applying in Victoria and under similar laws in the Commonwealth, such as the such as the Privacy Act, because the information can be categorized as follows: 

Personal information: information about a living identifiable or easily identifiable individual (including work related information or images). 

Sensitive information: information about a living individual’s race or ethnicity, political opinions, religious or philosophical beliefs, sexual preferences or practices, criminal record, or membership details, such as trade union or professional, political or trade associations. 

Health information: information about a living or deceased individual’s physical, mental or psychological health. 

Security and Confidentiality of Information 

Verbal or written information not stored by PN 

Staff and volunteers may become aware of information about particular women or their families and other circumstances concerning the women during the course of their work with PN. This could relate to women in prison or to ex-offenders or to their family members. It could also relate to their offences, their sentences or to the court processes. 

Such information is provided to PN in the context of a loving and caring relationship, where staff and volunteers seek to build trust with those we serve. To break this trust by breaching a woman’s confidence, (or her family’s), therefore goes against fundamental PN values and beliefs. It could also result in serious reputation damage to PN with the women, prison management, Corrections Victoria and PN’s stakeholders generally. 

It is paramount that any information obtained by PN about offending or ex-offending women and their families is kept confidential. Any information about offending or ex-offending women or their families obtained either verbally or in writing by PN staff or volunteers in the course of PN work is confidential and may ONLY be disclosed to PN staff members or volunteers, where this is required for PN to undertake its responsibilities. 

Accordingly, a breach of this policy is very serious and may result in disciplinary action being taken against the staff member or volunteer, in accordance with the PN Dismissal Policy. 

Information about womens’ families stored by PN 

It is important to note that the information and security of information laws apply to information gathered and stored or kept by organisations to undertake their work. Prison Network records or stores information of the above nature regarding the women or their families, are the names and addresses of womens’ families, so that PN may transport their children. Occasionally this could include particular health issues related to the children, details of Medicare numbers and their doctors. 

This information is stored by PN in Dropbox, in cloud storage. It is only accessible by staff; volunteers cannot access this information. The information is confidential and staff and volunteers can only disclose the names, addresses or ages of womens’ families to other PN staff or volunteers in order to undertake PN work and responsibilities. In most circumstances, this information has been provided to PN and is disclosed with the consent of a guardian, carer, parent or the women themselves. 

This type of information is password protected and stored in Dropbox 

PN staff may also keep notes about the women they are following up on, either in the prison or post release, which potentially includes information of a personal nature. This could also be information that are reports for court or references, that may also contain information of a personal nature. Staff members who keep these notes will retain them on their personal computers and password protect them, so there are two layers of security to the information, the password to access the computer and the password to access the specific document. 

PN keeps statistics on the numbers of women that attends its programs inside and outside prison. PN is required to report these numbers either to Corrections Victoria or to other entities, pursuant to the reporting requirement of the grant conditions or the entity. The information that is reported to CV contains a CRN and the name of the women who attend the PN programs. This information is password protected and accessible only by the CEO and the PN administrator on Dropbox. 

Personal information regarding staff and volunteers stored by PN 

The personal details of staff and volunteers of PN are stored in Dropbox and is only accessible by staff members. This information is confidential and only disclosed to others for the express purpose of undertaking PN business and responsibilities. If any disclosure is public, such as on the PN website or photos are taken at PN events and posted on social or other media, the information is either de-identified or the prior consent of the staff member or volunteer obtained. 

The PN Volunteer Co-ordinator keeps hard copy folders of information regarding each volunteer at her home. This is kept in a locked filing cabinet.