Scope

This policy applies to all employees, students, contractors, and volunteers as it relates to their employment, academic, or business relationship with the KGI.

KGI-affiliated entities, including schools, clinics, departments, practices, groups, etc., use of social media are not regulated by this document. Abiding by the strictest policy is considered the best option.

Purpose

Keck Graduate Institute recognizes that social media is an important and timely means of communication. Use of social media during working hours and as related to job functions should be self-moderated, and those who use social media must be aware that posting certain information is illegal. Offenders may be subject to criminal and civil liability, and adverse institutional actions. The purpose of this policy is:

  • To provide guidelines outlining how KGI employees, students, contractors, and volunteers can engage in the appropriate use of social media platforms;
  • To minimize the business, legal, and personal risks that may arise from an individual’s use of social media; and
  • To protect the privacy and safety of KGI patients, students, employees, and contractors.

Definitions

Personal Use for the purposes of this policy is defined as social media activity using your own personal or professional social media accounts.

Social Media refers to various types of interactive communities typically accessed through the World Wide Web or mobile device and computer applications (apps). The communities are usually characterized by user-generated content; user-shared content or areas designed for free and open discussion, or can be a mix of all three.

Social media includes, but are not limited to, blogs (Blogger, Blogspot, WordPress, etc.), photo and/or video-sharing sites and apps (YouTube, Flickr, Instagram, SnapChat, Vine, etc.), e-zines (digital magazines), wikis (Wikipedia), social networks (Facebook, Twitter, LinkedIn, Pinterest, etc.), video and audio podcasts [posted to the web or hosted by applications (ex.: iTunes)], ratings sites and apps (Urbanspoon, Yelp, Rate My Professor, etc.), and discussion sections of web pages or applications (comment section under articles on news or information websites).

General Policy

KGI Conduct Policies Also Govern Use Of Social Media

It is the policy of KGI that the use of social media will be done in conjunction with the principles of the KGI Honor Codes, the Clinical Code of Conduct, the faculty and employee handbooks, and compliance with all federal and state rules and regulations as well as the following delineated prohibited uses and best practices.

Individuals are responsible for their own use

Social media outlets, including discussion boards, may or may not be monitored or regulated. It is up to each user of a social media outlet or participant in a virtual discussion to regulate his or her content that is added or shared with the community.

Prohibited Uses

Social media postings must not violate HIPAA

You may not post the personal information or photograph of any patient on KGI rotation sites. Removal of an individual’s name does not constitute proper de-identification of protected health information. Inclusion of data such as age, gender, race, diagnosis, date of evaluation, types of treatment, or the use of a highly specific medical photograph (such as a before/after photograph of a patient having surgery or a photograph of a patient from one of the medical outreach trips) may still allow the reader to recognize the identity of a specific individual. Posting of patient information could violate state or federal laws such as the Health Insurance Portability and Accountability Act (HIPAA).

Social media postings must not violate FERPA

You may not post private (protected) academic information of a student or trainee. You may not post the personal information or photograph of any student/trainee at KGI within the context of a KGI event or interaction without obtaining permission from that person. Posting of inappropriate student/trainee information could violate federal laws. This policy does not prohibit a student/trainee from posting his or her own information. Additionally, the policy does not prohibit posting information or photographs related to non-KGI interactions and activities.

  • Social Media postings shall not be unprofessional nor discriminatory. You may not post vulgar, false, obscene, harassing statements, or statements disparaging the race, religion, age, sex, sexual orientation, or disability of any individual with whom you come into contact as a result of your role at KGI.
  • You may not disclose any financial, proprietary, or other confidential information of KGI.
  • You may not present yourself as an official representative of, or spokesperson for, KGI.
  • You may not utilize KGI’s trademarks or logos without permission of the Marketing Department of KGI.
  • You may not represent yourself as another person, real or fictitious, or otherwise attempt to obscure your identity as a means to circumvent the prohibitions included in this policy.
  • You may not utilize websites and/or applications in a manner that interferes with your work responsibilities. That is, do not tie up KGI or institutional partner computers or phone lines with personal business when others need access.
  • Faculty shall employ the highest professional and ethical standards in any social media interactions with students enrolled at KGI.

Violations/Enforcements

The disciplinary procedure for faculty and staff described in the KGI Faculty and Staff Handbooks is applicable to violations of this policy. Student disciplinary actions will be undertaken according to established policies and procedures within the school Handbook in which a student is enrolled. Failure to comply with the policy requirements may result in sanctions ranging from counseling to suspension pending termination. Violations of federal and state laws may also result in criminal or civil action undertaken by the government.

Employee Affirmation/Acknowledgement

This policy will be disseminated during annual compliance training. Each employee, student, and contractor will acknowledge the adherence to the policy at that time.

This policy shall not be construed to impair any constitutionally protected activity, including speech, protest, or assembly.

Guidelines For Ethical And Professional Behavior

General Guidance

  • Accessible postings on social media are subject to the same professional standards as any other personal interaction. The written nature, persistence, and potential accessibility of these postings make them subject to particular scrutiny.
  • By identifying themselves publically using social media, students and/ or employees of KGI are creating perceptions about the Institute. Students and employees must assure that all public content is consistent with the values and professional standards of the Institute.
  • Public postings on social media may have legal ramifications. Comments made by students or employees concerning patients, or who portray themselves, other students, faculty, or other colleagues in an unprofessional manner can be used by the courts or professional licensing boards, if applicable.
  • Unprofessional public postings by others on a social media can reflect poorly on the student/employee. Students and employees should monitor their sites and ensure that the content will not be viewed as unprofessional.

Social Media Best Practices/Permitted Uses

Individuals in the KGI community must make every effort to present themselves in a mature, responsible, and professional manner when utilizing social media. Communications must always be civil and respectful. Please be aware that no privatization measure is perfect and undesignated persons may still gain access to your networking site.

Further, litigation involving such issues is complex, as the content on social media sites is easily misconstrued, permanent, discoverable by courts, and utilized in these adversarial proceedings. Any digital exposure can “live on” beyond its removal from the original website and continue to circulate in other venues.

Therefore, think carefully before you post any information on a website or application, and consider your goals in participating. Make sure you are choosing the most relevant platform and adding value to the discussion. Listen before you engage and always be modest, respectful, and professional in your actions. To help facilitate these goals, the following best practices are encouraged:

  • Make sure your posts are relevant and accurate.
  • Make clear that you are speaking for yourself and not on behalf of KGI. You may consider adding a disclaimer such as “The views expressed on this (blog, website, etc.) are my own and do not reflect the views of my employer/school, KGI.”
  • You may also include a disclaimer that you are not providing medical advice when posting medical education information.
  • Seek permission from co-workers prior to posting any personal information or photographs related to KGI interactions or activities.
  • KGI discourages clinicians from having social media relationships with patients.
  • Include citations whenever possible to prevent copyright and intellectual property issues. Suggested Best Practices for e-Professionalism
  • Deletion of material from social media does not necessarily mean it is no longer available since, for example, search engines cache such content. This implies special care should be taken in posting material since it will persist.
  • Due to frequent updating of social media sites, it is advisable to check privacy settings regularly to optimize privacy and security.
  • Check privacy settings so that only people they choose have access to personal information.
  • Consider minimizing personal information on social media profiles such as addresses, phone numbers, social security numbers, PID numbers, passport numbers, driver’s license numbers, birth dates, or any other information that could be used to obtain personal records.
  • Make sure that any photos in which you are identified (“tagged”) are not embarrassing or professionally compromising. Student and employees should “untag” themselves from any photos that they cannot have removed. It is strongly suggested to refrain from “tagging” others without the explicit permission of those people.
  • Maintain the privacy of colleagues, faculty, and staff unless they have been given permission to use the person’s likeness or name on their site.
  • Always observe HIPAA regulations, which apply to all comments made on social media sites; violators are subject to the same prosecution as with other HIPAA violations.
  • Take all precautions normally used in public forums to maintain patient privacy when using social media.
  • Online discussions of specific patients should be avoided, unless on secure healthcare related networks, even if all identifying information is excluded. It may be possible for someone to identify the patient from the context of the discussion.
  • Under no circumstances is it appropriate or legal to post photos of patients or patient body parts on social media without the specific written permission of the patient. Be aware that even if permission from the patient to use a photo is granted, that photo may be downloaded and distributed by others, which may then violate the terms of the permission.
  • Interactions with patients through social media should be avoided as they provide numerous opportunities for violating privacy restrictions and may have legal consequences.

** Adapted and modified from the Guideline for Use of Online Social Networks for Medical Students and Physicians-in-Training, Indiana University School of Medicine and the Policy on Use of Social Networking Sites, University of Florida, College of Medicine and the University of Mississippi Medical Center Policy and Guidelines for Personal Use of Social Media.

Adopted by the KGI President’s Cabinet 4/21/14, formatted revision adopted 11/11/14