Polcity 1140 - Social Media

1140.10 This policy is to establish guidelines on the use of social media sites to be used by the San Mateo County Mosquito and Vector Control District (“District”) as an additional means of conveying District information to its residents, constituents, and community members and maximizing the promotion of District programs and services.

      1140.101 The intended purpose of establishing social media pages for the District’s use is to establish an interactive communication platform with local residents and to disseminate information from the District and about the District. This policy is also intended to mitigate associated risks from use of social media technology, where possible.

1140.20 The District has an overriding interest and expectation in protecting the integrity of information posted on its social media pages and deciding what is “said” on behalf of the District. This policy applies wholly to the District and all District employees or officials who use social media sites and/or technology on behalf of the District. Further, the District’s social media presence is intended to serve only as a limited public forum.

1140.30 All questions relating to this policy should be directed to the Public Health Education and Outreach Officer and/or the District Manager.

1140.40 This policy applies only to the creation and administration of social media accounts approved by the District for its own use. The personal use of other social media accounts by District officials or employees (e.g., an official or employee’s posting on non-District Facebook or Twitter accounts) are not governed by this policy.

1140.50 Definitions

      1140.501 Social Media – social media refers to the various activities that integrate technology, social interaction, and content creation. Through social media, individuals or groups can create, organize, edit or comment on, combine, and share content. Social media uses many technologies and forms, including social-networking, blogs, wikis, photo-sharing, video-sharing, podcast, social bookmarking, mash-ups, widgets, virtual worlds, microblogs, Really Simply Syndication (RSS) and more.

      1140.502 Official District Email Account – Email account provided by the District or approved external mailbox that is used for official District business.

      1140.503 Approved District Social Media Site – Approved District Social Media Site refers to social media platforms that the Public Health Education and Outreach Officer has assessed and approved for use by the District.

      1140.504 Post – An administrator submitted message/blog in the form of, but may not be limited to, text, videos, photographs, graphics, links (hyperlinks), documents, or any other form of content or communication posted on any Approved District Social Media Site.

      1140.505 Comment – A user submitted response to an administrator post on an Approved District Social Media Site.

1140.60 Responsibility

      1140.601 The District’s Board of Trustees will be responsible for approval of the District’s Social Media Policy.

      1140.602 The District Manager will review work plans for social media sites and may delegate this review function to the Public Health Education and Outreach Officer. The creation of content posted on behalf of the District on any Approved District Social Media Sites is ultimately the responsibility of the Public Health Education and Outreach Officer. Only the Public Health Education and Outreach Officer or other staff members designated by the District Manager are permitted to post on an Approve District Social Media Site on behalf of the District.

      1140.603 The Public Health Education and Outreach Officer will help District staff develop appropriate uses for social media, identify the best social media tools to achieve their goals, and define a strategy for community engagement using Approved District Social Media Sites.

      1140.604 The District is responsible for complying with all applicable federal, state, and local laws, regulations, and policies in connection with its use and administration of any Approved District Social Media Site. This includes, but is not limited to, adherence to established laws and policies regarding copyright, records retention, Freedom of Information Act (FOIA), First Amendment, Health Insurance Portability and Accountability Act (HIPAA), privacy laws, confidentiality of personnel information, and information security policies established by the District. This policy attempts to address the most common concerns in these regards, but employees should contact the District Manager with any questions regarding these areas. When needed, the District Manger will confer with District Counsel on these matters.

      1140.605 The Public Health Education and Outreach Officer will monitor content on each of the Approved District Social Media Sites to ensure adherence to the social media policy for appropriate use, message, and branding consistent with the goals of the District.

      1140.606 All official District presences on Approved District Social Media Sites are considered an extension of the District’s information networks and are governed by District policies, including e-mail, Internet usage, use of electronic media, and portable computer policies. In addition, the District’s presence on Approved District Social Media Sites is also subject to the District’s policies on harassment, discrimination, political activity, and customer relations.

      1140.607 Employees representing the District via Approved District Social Media Sites must conduct themselves at all times as representatives of the District. Employees who fail to conduct themselves in an appropriate manner shall be subject to appropriate disciplinary actions.

      1140.608 This policy may be revised at any time upon approval by the Board of Trustees.

1140.70 Authenticity Establishment

      1140.701 Approved District Social Media Sites shall be created and maintained with identifiable characteristics identifying them as official District sites. The name “San Mateo County Mosquito and Vector Control District” and/or the official District logo must be displayed on any Approved District Social Media Site.

      1140.702 Approved District Social Media Sites shall be created and accessed using an official District email account.

      1140.703 The District’s official website at www.smcmvcd.org will remain the District’s primary source and means of internet communication. To the extent possible, a link to the District’s official website and the District’s general contact information shall be included on any Approved District Social Media Site. Wherever possible, Approved District Social Media Sites should contain a link back to the official District website for forms, documents, online services, and other information necessary to conduct business with the District. Information posted by the District on Approved District Social Media Sites will supplement, and not replace, required notices and standard methods of communication.

      1140.704 Approved District Social Media Sites must make clear that they are maintained by the District and state that they follow the District’s social media policy. To the extent possible, a link (hyperlink) to the District’s Social Media Policy must be displayed on any Approved District Social Media Site.

      1140.705 The District Manager and the Public Health Education and Outreach Officer shall maintain all login and password information related to any Approved District Social Media Site.

1140.80 Site Content and Management

      1140.801 Approved District Social Media Sites are to be used for informational purposes and all content must pertain to the District and/or District business, services, programs or events. The District shall have full permission and rights to any content posted by or on behalf of the District, including all photographs and videos.

      1140.802 Approved District Social Media Sites shall be maintained consistent with the Brown Act, the Political Reform Act, and the California Election Code. Members of the District’s Board of Trustees and any other appointed or elected officials shall not post or respond to any posts, comments or publications on any Approved District Social Media Site, or use any Approved District Social Media Site to blog or engage in serial meetings, or otherwise discuss, deliberate, or express opinions on any issue within the subject matter jurisdiction of the District, or for any political purpose. Personal use of other social media accounts by District officials or employees (e.g., an official or employee’s postings on non-District Facebook or Twitter accounts) is not governed by this policy.

      1140.803 With respect to Approved District Social Media Sites, the Public Health Education and Outreach Officer shall be responsible for posting content on behalf of the District, monitoring content, responding to comments where appropriate, and reviewing site activity for exploitation or misuse. All Approved District Social Media Sites must provide a mechanism for the District to remove posts or prevent the posting of content that violates this policy.

      1140.804 To the extent that Approved District Social Media Sites allow users to post comments or responses to official posts by the District, the Approved District Social Media Site must include a list of the applicable guidelines being applied by the District to the forum and should include a statement that all posts are subject to this policy, as well as the host site’s own terms of use. Each page should also indicate that it is intended only to create a limited public forum subject to the restrictions set forth in this policy.

      1140.805 Content posted on Approved District Social Media Sites may be considered public records subject to disclosure under California’s Public Record Act (“PRA” – Government Code §§ 6250 et. seq.). Any content maintained on any Approved District Social Media Site that is related to District business, including a list of subscribers, posted communication, and communication submitted for posting, as well as any deleted content, may be a public record subject to disclosure. All such content must be retained pursuant to the Public Records Act and the District’s retention policy. PRA requests for the production of posts or deleted content on an Approved District Social Media Site shall be referred to District Counsel for review and response.

      1140.806 Content posted on any Approved District Social Media Site shall relate solely to matters of District business. A comment or post by a member of the public is the opinion of the commenter or poster only, and does not imply endorsement of, agreement with, or reflect the opinions of, the District.

      1140.807 Any content posted by external and authorized internal users on any Approved District Social Media Site may be subject to removal if it contains:

    1140.8071 Profane, obscene, violent or pornographic language or content;

            1140.8072 Content that promotes, fosters or perpetuates discrimination or harassment on the basis of race, age, religion, gender, national origin, sexual orientation, or any other category protected by local, state or federal law;

            1140.8073 Content that constitutes sexual harassment of any member of the public or District employee or official;

            1140.8074 Solicitations of commerce or advertisements, including promotion or endorsement;

            1140.8075 Promotion or endorsement of political issues, campaigns, ballot measures, groups or individuals;

            1140.8076 Conduct that constitutes or encourages illegal activity;

            1140.8077 Information that may tend to compromise the safety or security of the public or public systems or of the District’s technology resources;

            1140.8078 Content intended to defame any person, group or organization;

            1140.8079 Content that violates a legal ownership interest of any other party, such as trademark or copyright infringement;

            1140.80710 False, vicious or malicious statements concerning any employee, the District or its operations;

            1140.80711 Violent or threatening content;

            1140.80712 Confidential, sensitive or proprietary information, including personnel information such as home addresses, phone numbers, social security numbers, dates of birth or driver’s license numbers; and

            1140.80713 Comments not related to District posts, business, information, announcements, events or comments not related to the original topic, including random or unintelligible posts.

1140.90 The above list is not necessarily exhaustive and the District reserves the right to remove or restrict any post or comment on any Approved District Social Media Site that violates the purpose or spirit of this policy.

1140.100 Unacceptable content and repeat individual violators shall be removed from the Approved District Social Media Site and/or individual violators may be prohibited from making any further or additional posts on any Approved District Social Media Site. The District’s Counsel shall be consulted on any legal issues with respect to the removal of content or blocking of individual users.

1140.200 Records Management

      1140.201 The District’s use of its Approved District Social Media Sites shall be documented and maintained in an easily accessible format that tracks account information.

      1140.202 The Public Health Education and Outreach Officer is responsible for the creation, administration and deactivation of Approved District Social Media Sites.

      1140.203 Content deemed inappropriate or technically destructive shall be promptly documented (screenshot/printout), saved pursuant to District policies and procedures regarding record retention, and then be removed immediately from any Approved District Social Media Site. The District’s Counsel should be consulted on any potential legal issues.

1140.300 Network Security

      1140.301 The District’s information technology (“IT”) staff shall have security controls in place to protect District information and technology assets against potential destructive technical incidents.

      1140.302 Perceived or known compromises to the District’s internal network and/or its Approved District Social Media Sites shall be promptly reported to the District Manager.

      1140.303 Computer, laptops and mobile devices used to administer Approved District Social Media Sites shall have up-to-date software to protect against destructive technical incidents, including, but not limited to, cyber, virus and spyware/adware attacks.

Legal Review:          Kevin Siegel, Assistant General Counsel, and Traci Park, Special Counsel (Burke, Williams & Sorensen, LLP)

Board Approval:      May 13, 2015