HHS General Guidance for Utilization of New and/or Social Media

[Note:  This is a working draft.  It is to be followed even as it is modified and updated to reflect both technology and experience.  It is anticipated that Offices will augment this guidance to reflect their own (more restrictive) practices.]

We’d like your feedback! Please share your thoughts on the draft guidance.

• Introduction
• Scope
• Licensing
• Approvals and Notifications
• Branding
• Comments & Commenting
• Applicable Policies

Introduction:

HHS encourages the use of appropriate Social Media/Web 2.0 (SM/W2.0) technologies to enhance communication, collaboration, and information exchange in support of HHS’s mission.  These tools are evolving rapidly and are shaping how we work with our customers, business partners, other government agencies, and the public.

The decision to use a social media tool (or combination of tools) must be based on a strategic communications plan and must address the commitment of resources necessary to manage and maintain the public engagement.

The guidelines established in this document have been designed to ensure that official HHS websites and social media accounts present accurate, credible information and that personal opinions are not misinterpreted as official HHS positions. This document also provides guidelines for employees’ unofficial (i.e. personal) use of SM/W2.0 technologies and how to use SM/W2.0 technologies in a way that does not pose a threat to HHS IT security.

Scope:

For the purpose of this set of guidelines, SM/W2.0 technologies are defined as XML feeds, blogs, wikis, social networking sites, discussion forums, collaborative research Web sites, comment features for news or videos or other content posted to Web pages, and other ways of directly interacting with the public.

Licensing:

HHS, through Web Communications and New Media Division (WCD), is signing federally negotiated agreements with social computing providers that make it possible for Department employees to use these technologies for official HHS use while meeting current legal requirements. 

Most SM/W2.0 services, using a “click here to agree” method, require the acceptance of standard terms of use to open an account.  Many such terms of use contain provisions that Federal agencies are forbidden by law to accept.  Do NOT unilaterally agree to any license (Terms of Service agreement)not already signed by HHS without consulting WCD and the Office of General Counsel (see list at http://www.newmedia.hhs.gov/standards/tos).

Approvals and Notifications:

The level of approval required to use social media is media specific.  All official uses of social media must be approved by program or office management (with the level of approval to be determined by management) in consultation with the appropriate communications office.  If the communication involves the discussion of policy, management, budget issues or would otherwise be classified as “official communication,” it should be reviewed by the appropriate communications office.

Certain high-profile or public-involvement (i.e., opportunity for comment) media require notification of the WCD and may require approval of either WCD or the Assistant Secretary for Public Affairs (ASPA). 

Social media requiring notification or approval of WCD or ASPA include, but are not limited to, blogs, Twitter, YouTube, Facebook, and MySpace.  Additional information about certain applications is available at www.newmedia.hhs.gov/tools.  WCD’s Center for New Media will maintain a directory of social media accounts utilized by the Department, organized by media and by topic, at the above mentioned Web site.  Including your outreach in an HHS directory documents the legitimacy of your SM/W2.0 presence.

Branding

Departmental social media sites and content must clearly identify ownership or sponsorship through the use of Department or OPDIV branding.  Branding must be part of the approval process.

Employees establishing personal SM/W2.0 accounts must obtain management approval before incorporating Agency identifiers in their profile or user name (i.e., scott@cms).

Comments & Commenting:

A number of social media allow or encourage the submission of written comments (see YouTube guidance for handling of video comments).  HHS encourages this public interaction with the following caveats:

• All comments must be reviewed and cleared (moderated) before they are posted to or included on an HHS page or account. 
• The comment policy must be clearly stated or linked (see http://www.newmedia.hhs.gov/standards/comment_policy.html#comment for model comment policy).
• Comments must not be posted if they contain:
  • Partisan political views
  • Commercial endorsements
  • Discriminatory, racist, offensive, obscene, inflammatory, unlawful or otherwise objectionable statements, language or content.
• Records must be kept of all comments received, whether approved for posting or not.
• Individuals commenting in their official capacity on any platform must identify their Agency relationship.
• In general, employees participating in their official capacity on SM/W2.0 sites should follow the same rules of behavior they would when participating in a public meeting.

Applicable Policies:

Use of social media technologies must follow the current laws and guidelines that govern information and information technology. These statues and regulations include, but are not limited to Section 508 (accessibility), records management, privacy, usability of data, security, intellectual property, the Federal Advisory Committee Act (FACA), the Paperwork Reduction Act (PRA), and information quality.

It is essential to be as accurate as possible. While there is often a tradeoff between speed of communication and accuracy, HHS employees are expected to fact check communications and whenever feasible to correct inaccurate information about HHS work (especially on HHS Web sites) that is brought to their attention.

Some SM/W2.0 web sites improperly use copyrighted images and videos. HHS employees may not use or post copyrighted materials without written permission from the copyright owner. 

Do not include surveys, polls, questionnaires, etc., unless the questions have received OMB Paperwork Reduction Act clearance.  The Paperwork Reduction Act prohibits certain information collections by the HHS without prior approval by OMB.

SM/W2.0 content that is not accessible to people with disabilities must also be posted in accessible formats on official HHS Web sites.  This ensures that our use of SM/W2.0 technologies remains in compliance with Section 508 of the Rehabilitation Act of 1973, that people with disabilities always have an accessible version of the content, and that the official version of content is located on a government Web site.

Do not solicit consensus advice from the public using SM/W2.0 technologies.  The Federal Advisory Committee Act (FACA) prohibits agencies from receiving consensus advice from de facto committees or groups that arise outside of the structure and public scrutiny of a formally established advisory committee.

Make sure that content stored on SM/W2.0  web sites is secure and adequately maintained, that there is no unauthorized disclosure of personal privacy information, and that records are retained consistent with the HHS Web records policy http://www.hhs.gov/web/policies/webpolicies/webrecords.html. [Note: WCD is working with the Department records Officer to update this policy to reflect SM/W2.0.]