The Charity Commission are consulting on draft guidelines for trustees around social media use. https://www.gov.uk/government/consultations/draft-guidance-charities-use-of-social-media. This is an area of importance for small charities, but these guidelines will not be a great deal of use for trustees or staff.
This blog sets out my thinking as a small charity CEO and someone who does use social media personally to comment on political and charity topics amongst other things. I have looked at the main areas the commission think that the guidelines should cover and then at the specific area of personal accounts of staff, trustees, or volunteers.
To get other sector views I would start with this Twitter thread from Chris Walker at NCVO
The guidance states that
“If you use social media:
- adopt a social media policy so that you have internal controls in place that are appropriate, proportionate and are clear to everyone at the charity using social media
- ensure you use social media only to help you achieve your charity’s purpose (what your charity was set up to do) and in a way that is in your charity’s best interests
- comply with relevant laws and regulations
- any campaigning or political activity that you do on social media complies with the rules on political activity and campaigning
- ensure your processes help you keep people safe online. Read the “Operating online” section of our guidance on safeguarding”
Looking at these 5 bullet points
Is a policy necessary?
Before we all rush to produce yet another policy that may well never be used, we need to think what should be in it and what real difference will it make. The guidance does suggest some headings for the policy but there is no detailed guidance for a small organisation without the expertise to develop something from scratch. Social media is not a black and white and works best as a conversation. It is also often very reactive and fast moving and is used by organisations for many purposes.
To make the most from social media there has to be trust and understanding in the team. In a small organisation this is often easier to manage, and trustees will be closer to the staff. It is important that trustees engage with the organisations social media to help boost reach and impact.
CCVS have actively decided not to develop a social media policy so that staff are not too constrained and can react, but we have updated our Employee Handbook to state:
“You must not make reference to the organisation or its services, or represent yourself on behalf of the organisation on social media, nor publicise photographs of our work online without formal permission from the organisation to do so (even where this work was undertaken by you.)”
Apart from this we have had a conversation, more detailed with the people with access to the channels, but all staff know what the different channels are for. This comes back to the team buying into the vision, mission and values of the organisation in all their interaction with stakeholders on social or in real life. We are a small team, we work on a basis of trust in all we do and we put in a minimum amount of oversight so that team members can exercise their discretion and creativity.
Only use social media to further your purpose.
We have to realise that as charities we have responsibilities beyond our primary purpose and we should be commenting and raising awareness on these.
As an organisation we a have a set of values that is not simply linked to our purpose but also related to our impact on the world. This will mean that charities will comment on issues that are reflected in their values, this may be liking posts or reposting content, of commenting. This is part of our wider responsibility as an organisation.
One of our values is ‘sustainability’ and as an organisation we think it is important that we talk about how we and others could help around the climate crisis, this might be about encouraging groups to think about things or change their practices to reduce climate impact, but it might also be about bigger things not directly linked to our primary purpose.
Don’t break the law
I am not arguing with this and don’t think that it needs to be in a policy.
But sometimes charities need to push the boundaries. If your purpose is to support refugees and highlight the issues impacting them should you post pictures of people crossing the channel in small boats to highlight what is happening?
Keep to the political campaigning rules.
These have been in place for a number of years and the whole area is mainly an issue for large charities and the guidelines have less impact on small ones, especially those that work locally.
As an organisation we campaign on issues that are relevant to our purpose, and part of this includes amplifying messages from local groups that could have a political element. We also use social media to speak to MPs and local politicians. We do not advocate for one party but we may call out candidates who do not respond to local hustings etc that are set up by members, and we may call out or praise a party locally. We are funded by different local authorities with different viewpoints and have to balance this with our role to ‘speak truth to power’.
This issue should not be part of a social media policy but covered in how you manage campaigning and communications more generally.
Keep people safe online
This is very important and is something that small charities need to give more thought to. This is about keeping the charity and all those involved with it safe. The government and others have done some fantastic work in this area producing useful and practical guides such as these from the National Cyber Security Centre.
Small Charity Guide to Cyber Security
Social media and how to use it safely
All staff should be made aware of these guides as should volunteers and trustees especially if they are posting on the charity’s sites.
I start to have a real problem with this section of the guidance that states:
“What to do about problematic content posted or shared by anyone connected to the charity.
Trustees, employees or volunteers are free to post or share personal content and viewpoints on their own social media accounts.
Sometimes there are risks that an individual’s posts are interpreted as reflecting those of a charity. For example a trustee, employee or volunteer could post inappropriate content:
- using a personal account where they can be associated with the charity, either through mixing both personal and professional content or because they list their workplace or role.
- using an entirely personal account that could reasonably be linked to the person’s role at the charity.
As a trustee you are responsible for identifying and managing risks like this, such as by being clear what your rules are, which may be set out in your social media and/or HR policies. This is not intended to prevent general personal use of social media but to help make clear when the charity may have a legitimate concern as the employer.
If personal content has brought negative attention to the charity, consider what actions you may take based on how problematic the content is and what your policy says.”
Locally (and nationally) many people know my link with CCVS, and I have never hidden this on social media. I have worked in the sector over 30 years and been at CCVS in different roles for 11 years, over this time I have spoken to lots of people in person and online including on different social platforms. My personal profile does not mention CCVS but it wouldn’t take genius to make the connection if you read my posts.
Does this mean the trustees can dictate what I write? If I break the law then there could be a case for gross misconduct if it were for an area that had a direct impact on the charity. But if I decide to attend a protest and am arrested, or I tweet overtly political content this is not something the trustees can influence. The law around freedom of speech or the right to protest trump any organisational guidelines.
As a small organisation we operate on a basis of trust between, staff, trustees, volunteers and partners. I have CCVS in my core so would no more disparage the organisation than I would a family member or friend. We can not set rules and guidelines for all situations and we have to rely on trust, common sense, and the ability to have a conversation if there are issues to be addressed.
I think that an over prescriptive social media policy will reduce the impact that this form of communication can have across all areas of a charities work. I think that including a basic statement in a handbook, a policy, or a contract is sufficient. I also think that the trustees of a charity need to understand social media and that some if not all should follow and engage with their charities accounts. Most of all I think trustees need to invest in management that is by consent and not about command and control.
Written by Mark Freeman CEO