I. Purpose: To provide guidelines outlining how Vanderbilt University Medical Center (VUMC) supports institutional communication goals through social media platforms.
This policy is intended for internet activities that associate or identify a VUMC faculty or staff member with Vanderbilt, use Vanderbilt email addresses, or discuss Vanderbilt. In keeping with the Electronic Communications and Information Technology Resources policy (HR-025), Vanderbilt email addresses should not be used in conjunction with unofficial or personal social media accounts and profiles. This policy is not intended to guide online communications when employees do not associate or identify themselves with Vanderbilt.
III. Definitions: Content Owners, for the purpose of this policy, are those assigned the responsibility of maintaining, monitoring, and moderating a VUMC social media platform. Official communications refer to those done in VUMC’s name, (e.g., a Vanderbilt Health Facebook page).
A. Content Owner – Assigned by department as the individual responsible for monitoring and maintaining web content.
B. Moderator – Assigned by Content Owner and/or department as the individual for moderating comments and postings by internal and external users, including deleting comments and postings that do not meet the criteria set forth in this policy.
C. Social Media Platforms – Technology tools and online spaces for integrating and sharing user-generated content in order to engage constituencies in conversations and allow them to participate in content and community creation. Examples are Facebook, Twitter, LinkedIn, Google+ and YouTube.
IV. Specific Information:
A. Official Institutional Social Media Communications:
1. Because of the evolving nature of social media platforms, these guidelines do not attempt to name every current and emerging platform. Rather, they apply to those cited and any other online platform available and emerging, including social networking sites and sites with user-generated content. Examples include, but are not limited to the following:
2. Institutional representation via online social media platforms can only be initiated and authorized through efforts of the Strategic Marketing department, and the Vanderbilt School of Medicine and the Vanderbilt School of Nursing. Any sites or pages existing without prior authorization as required above are subject to review when discovered and may be amended or removed.
3. Content Owners, as named by their departments or department’s leadership, are responsible for posting and using content and maintaining compliance with VUMC Credo behavior, HIPAA (Health Insurance Portability and Accountability Act) and policies related to Conflict of Interest, Privacy, Security, Safety and Human Resources, and FERPA (Federal Education Records Protection Act). Content Owners are also required to keep abreast of changes in policies or functionality of the social media platforms in use and maintain compliance with terms of service.
4. Content Owners are responsible for monitoring and maintaining web content as follows:
a. Content is current and accurate.
b. Content Owners engage in communications that are acceptable in the VUMC workplace and respect copyrights and disclosures. Proprietary financial, intellectual property, patient care or similar sensitive or private content may not be revealed.
c. Content Owners are responsible for gaining the expressed consent of all involved parties for the right to distribution or publication of recordings, photos, images, video, text, slideshow presentations, artwork, and advertisements whether those rights are purchased or obtained without compensation.
d. Content Owners are responsible for constantly monitoring postings and comments to social media sites, and for deleting postings that do not adhere to our policies.
5. Content Owners and/or Moderators sign a Content Owner/Moderator Terms and Agreement Form. This form is renewable annually and is monitored by Strategic Marketing. (See Appendix A).
6. My Health at Vanderbilt is a secure communications portal and the authorized channel to support messaging and dialogue with patients and their clinical care providers.
B. Guidelines for Online Professional or Personal Activity:
Online social media allows VUMC faculty and staff to engage in professional and personal conversations. These guidelines apply to faculty and staff who identify themselves with Vanderbilt in social medical venues such as professional society blogs, LinkedIn, Google+ and/or Facebook, for deliberate professional engagement or casual conversation.
1. Follow the same VUMC Credo behavior, HIPAA, Conflict of Interest policy, Privacy and general civil behavior guidelines cited above including respecting copyrights and disclosures, and not revealing proprietary financial, intellectual property, patient care, or similar sensitive or private content.
2. If VUMC faculty/staff identify themselves as a member of Vanderbilt faculty or staff in any online forum, faculty/staff make it clear that they are not speaking for Vanderbilt, and what they say is representative of their individual personal views and opinions and not necessarily the views and opinions of Vanderbilt.
3. VUMC Faculty and staff are thoughtful about how they present themselves as a VUMC faculty or staff member in online networks. By virtue of identifying oneself as a part of Vanderbilt in such a network, faculty/staff connect themselves to, and reflect upon, VUMC colleagues, managers, and even VUMC patients and donors.
4. Remember that all content contributed on all platforms becomes immediately searchable and can be immediately shared. This content immediately leaves the contributing individual faculty/staff members’ control forever.
If someone or some group offers to pay faculty/staff for participating in an online forum in their VUMC role, offers advertising for pay and/or for endorsement, this could constitute conflict of interest, and VUMC policies and guidelines apply.
6. If someone from the media or press contacts faculty or staff about posts made in online forums that relate to Vanderbilt in any way, faculty/staff alert their manager/leadership and contact News & Communications before responding.
7. If a patient or family member posts complaints about service or other issues, review and follow the Social Networking Response Guide (See Reference Work).
8. Job postings follow Vanderbilt’s Human Resources (HR) established processes. Social Media may not be used in place of HR processes.
9. Strategic Marketing, News & Communications VUSM, and VUSN provide official VUMC and/or VUSM and VUSN information that may be appended to social media sites (See Reference Works).
VUMC Policy Manual. (2013). Retrieved from https://mcapps.mc.vanderbilt.edu/E-Manual/Hpolicy.nsf?OpenDatabase.
Operations Policy Manual
OP 30-10.02 Conflict of Interest – Conflict of Commitment
Information Management Policy Manual
IM 10-30.01 Confidentiality of Protected Patient Information
IM 10-30.12 Sanctions for Privacy and Information Security
Social Media Toolkit for VUMC. (2013). Retrieved from http://www.mc.vanderbilt.edu/socialmediatools
Responding to Posts – Social Network Response Guide
Moderator Terms and Agreement (Apply for Account)
VUMC Compliance Website. (2013). Retrieved from www.mc.vanderbilt.edu/compliance/indexhome.html
VUMC Privacy Office. (2013). Retrieved from http://www.mc.vanderbilt.edu/root/vumc.php?site=hipaaprivacy&doc=11584