Social Media Policies and Best Practices for UCSF Hosted or Branded Accounts

Social media is an important communication tool to tell the UCSF story. Through institutional participation in online media, the UCSF message reaches wide audiences and UCSF can impact more lives. However, these channels come with risks and liabilities.

UCSF’s guidelines for the use of social media ensure that laws are being followed and that the university is accurately and consistently represented in such communications. University employees who represent UCSF in an official capacity on social media must understand the impact of these tools when communicating about the work and mission of UCSF. These social media guidelines apply to all UCSF community members who participate in university-branded or -sponsored social media profiles on any social platform, including but not limited to: Instagram, YouTube, TikTok, LinkedIn, Facebook Groups and Pages, Tumblr, Twitter, Reddit, Snapchat, and blogs.

Conduct on social media for UCSF-hosted accounts must abide by all other UCSF policies and guidelines including, Campus Administrative Policies, the Campus Code of Conduct, and UCSF Brand Identity Guidelines.

Official University-Sponsored Blogs and Social Media

These guidelines cover all types of University-sponsored social media, including those that educate on disease states, such as the Memory and Aging channel on YouTube, and those that promote a program or provide school information. One example is the UCSF Imaging Twitter account.

If you are participating in UCSF-sponsored social media, it is essential that you follow institution-wide social media policies and obtain the necessary approvals.

NEW SOCIAL MEDIA ACCOUNTS

University-sponsored social media profiles must be approved by the Office of Communications. UCSF Health Marketing must also approve any social media profiles involving UCSF Health clinical services. You may apply for an account with UCSF Health marketing here.

Follow these steps to set up a UCSF-hosted social media account:

1. Submit your new account proposal to [email protected]. This secures approval from the UCSF Social Media team to become an official UCSF account.
2. Follow the permitted use of UCSF name.
3. Set up your social media handle based on our naming convention best practices:

• For campus-affiliated accounts, handle names should begin with “UCSF” followed by the department/group name, i.e. “UCSFNeurosurgery”
• Verify that the word combination does not spell anything with an unintended meaning, such as “UCSFArts”
• Avoid acronyms, underscores and periods if possible, such as “@UCSFDOR“, “UCSF_school_of_nursing” etc.

Please direct any questions regarding approvals, legal responsibilities, privacy policies and logo usage to [email protected].

Special note for student government and registered campus organizations: Student organizations must observe University of California Policies Applying to Campus Activities, Organizations, and Students, which can be found here. For rules regarding the use of the University of California name, please refer to local implementation procedures for Use of the UCSF Name.   

For inquiries regarding UCSF Health and UCSF Benioff Children's Hospitals, please contact UCSF Health Marketing here.

Once you have received approval from the Office of Communications:

UCSF-Hosted Social Media Policies

1a. Approvals

Your department chair or dean must also approve a University-sponsored social media profile. The sponsoring department or school is responsible for ensuring that if the website contains any personally identifiable or protected health information, it is compliant with all privacy laws. The sponsoring department or school is responsible for ensuring that the content of the website is appropriate and does not cause damage to UCSF’s reputation.

1b. Consent

If you plan to post photos or videos, or patient information in any format, including written, you are responsible for obtaining appropriate authorization and consent forms from all such persons in the photos or videos, including patients, employees, faculty, staff, students and visitors.

• If you have any questions about authorization or consent related to news media, please contact UCSF News Media (476-2557).
• If you have any questions about consent, please contact Medical Center Risk Management (415-353-1842). If you have any questions about privacy laws, contact the Privacy Office (415-353-2750) or the Office of Legal Affairs (415-476-5003).

All consent forms must be maintained in the department or the patient’s medical record for six years after the last day the site is active.

If your site includes any information regarding disease states, treatment avenues, clinical trial research, or other information of interest to a patient audience, the site must include disclaimer language. Please consult with the Office of Legal Affairs for appropriate language.

• Remember, even if you refrain from mentioning a patient by name on a social media site, if there is a reasonable basis to believe that the person could still be identified from the information you have shared, then its use or disclosure could constitute a HIPAA/Privacy violation, resulting in personal and UCSF liability, penalties and fines.
• Closed groups and private messages on social media channels (such as Facebook chats or Twitter direct messages) are not secure channels for communication, and should not be used to communicate with or about patients.

1c. Comments on social media platforms

If you plan to include the ability for the public to comment, please contact the Office of Legal Affairs (415-476-5003). You should be aware that, because of UCSF’s status as a public entity, creation of any public discussion forum may invoke free-speech issues, thereby limiting your ability to edit the content of comments made by the public. Threatening or obscene comments may be deleted, as may spam, posts promoting illegal activities or copyright infringements. However, complaints about the university, its employees, its facilities or practices may not be deleted without approval from UCSF legal counsel.

If you plan to include the ability for the public to comment, you must include disclaimer language. Please consult with the Office of Legal Affairs for appropriate language.

You may also receive comments or messages from individuals seeking healthcare information or guidance. UCSF’s social media channels cannot be used to solicit health-related information from a user, such as asking someone to clarify a health issue. UCSF’s social media channels also cannot be used to offer diagnostic or treatment advice, such as recommending that someone take aspirin for a headache. In situations in which someone asks for guidance on a health-related issue, you can direct the person to a UCSF clinic to make an appointment or recommend that they contact an authorized healthcare provider.

1d. Advertising

Selling of advertising by departments or programs is prohibited on UCSF-sponsored social media accounts. Departments and programs using blogs and social media should not include content that could create any impression that UCSF is endorsing a particular product or service.

1e. Abiding by the UCSF Campus Code of Conduct

The UCSF Campus Code of Conduct articulates the values and ethical practices collectively embraced by the UCSF campus community. It is the expectation that all members of the campus community will exercise integrity and highly ethical conduct when using social media. Included in the Code of Conduct, and particularly important in social media, is respect for copyright laws.

Trademark and copyright laws apply to social media in most of the same ways that they apply to traditional publishing. Citing the source of an image, audio track or video does not substitute for obtaining permission. Failure to obtain permission to use a copyrighted photo could result in legal action.

See the complete UCSF Code of Conduct Campus Policy. The Code of Conduct, along with school and department-level Code of Conduct standards, applies equally to content and use of UCSF-sponsored blogs and social media.

1f. Content Suspension

The University reserves the right to suspend the use of or modify content on UCSF-sponsored blogs and social media sites within University policy and applicable law.

1g. Monitoring and Updating

The owner of the site (assigned by the department chair) is responsible for monitoring, maintaining and updating content to ensure accuracy and for addressing public comments as they arise.

2. Representing UCSF in Social Media

There are times when UCSF representatives speaking for UCSF will want to publish comments on others’ blogs, channels or posts in order to correct misstatements of facts about UCSF or its programs, or comment on issues that are being reported in the press. These types of posts should be made only by or in consultation with the Office of Communications or other key University communicators to ensure that UCSF is speaking with one voice on issues of public concern. All postings of this type should clearly identify the poster as an employee of UCSF who is speaking on behalf of UCSF.

UCSF employees who choose to comment as an individual on issues affecting or involving the University should make clear that their comments do not represent the University’s position or voice. Example: “All comments made here are made in my individual capacity and not on behalf of UCSF, and are not reviewed or approved by UCSF.”

If you have any questions about these UCSF guidelines, please contact the Office of Communications or the Office of Legal Affairs (415-476-5003).

References:

UCSF Code of Conduct

UCSF Confidentiality, Access, Use and Disclosure of Protected Health Information and Patient Privacy, Medical Center Policy No. 5.02.01

UCOP Electronic Communications Policy

UCSF Brand Identity Guidelines

UCOP Use of Name Policy No. PACAOS-Appendix-B

UCSF Use of Name Campus Policy No. 050-13

Social Media Conduct and Best Practices for UCSF Student, Employee, and Faculty Personal Accounts

UC San Francisco encourages and promotes community involvement in all online communications. The below practices help UCSF community members create meaningful conversations while ensuring the appropriate representation of institutional and personal views.

You should assume that all of your digital and social media behavior is or could become visible to the public, and deleting things is not a reliable way to remove them from the public record. Current, prospective, and former members of the UCSF community such as employees, patients, students, and others may see what you post. Practice common sense.

Failure to adhere to the below policies may constitute a violation of UCSF PRIDE values or a HIPAA violation, and disciplinary or legal action may be pursued.

Code of Conduct

Respect Confidentiality: When discussing UCSF, limit discussions to matters of public record. Do not disclose confidential or private information or speculate on the future of UCSF and its practices. Do not speculate on the future of UCSF and its practices.

The Offices of Technology Management (415-353-4462) and Legal Affairs (415-476-5003) are available for questions about what information is considered proprietary.

Respect Consent: Never post photos, videos or information about others without their consent, even if there is no identifying information in the photo. This includes fellow students, colleagues, patients, friends, family, and anyone else you encounter in a UCSF setting be it professional or instructional.

Respect Jurisdiction: Never speak on behalf of UCSF unless you have been specifically authorized and requested to do so by the Office of Communications. Do not portray yourself as a spokesperson, or even an unofficial spokesperson, on issues relating to UCSF.

Do not use “UCSF” in your handle name or use the UCSF logo or branding in your profile. You may not use your University title in any way that would imply that you are speaking for the University.

All non-UCSF sponsored social media profiles must carry a variation of the following disclaimer if the owner plans to use their UCSF title or affiliation in their profile:

“All comments here are made in my individual capacity and not on behalf of UCSF, and are not reviewed or approved by UCSF.”

Or

“The participant is ______ [a faculty member, staff or student] at UCSF. However, the views and opinions expressed herein do not necessarily state or reflect those of The Regents of the University of California, UCSF, UCSF Health, or any entities or units thereof.”

Respect the Law: Do not post content that violates any federal or state laws and regulations. Obtain permission to use or reproduce copyrighted content.

Respect Political Speech Limits: As a state entity, UCSF is subject to laws regarding political speech. The University may not endorse, oppose, or contribute to political candidates, nor may University resources, including University-paid time or equipment) be used for campaign purposes in connection with ballot propositions.

While the University does not restrict any member of our community from exercising their right to engage in personal political activity, no member of the community may use UCSF facilities or resources (including time on the job) for political purposes, except as specifically permitted by University regulations. In addition, care should be taken to avoid creating any misperception of the University's endorsement of a particular political position.

You must avoid any improper inference of University endorsement of a particular position. A University employee may use his or her University title for identification purposes only and should include a disclaimer of University endorsement if the context might reasonably cause confusion as to whether a political endorsement is made in an official or unofficial capacity. To avoid creating such a misperception, many of those endorsing political campaigns simply list themselves by name and location – for example, “Dr. John Smith, Sacramento.”

These limitations in no way constitute prohibitions on the right to express political views by any individual in the University community. Members of the University community are encouraged to participate in the political process, including supporting candidates and taking positions on ballot measures using their personal resources on their own time.

For more information, please review UCSF's advocacy guidelines.

Respect PRIDE Values: Be respectful. Do not post material that is profane, libelous, obscene, threatening, abusive, harassing, hateful, defamatory or embarrassing to another person or entity. As a UCSF community member, your online behavior should adhere to the same UCSF code of ethics as it would offline. Posts and comments made from personal accounts may be grounds for discipline if they are found to violate employee Codes of Conduct, especially if they place the university at legal risk. Examples may include harassing a coworker or violating HIPAA and/or CMIA.

Additional Policies for Health Care Providers: HIPAA and CMIA

Per the Health Insurance Portability and Accountability Act (HIPAA) and California’s Confidentiality of Medical Information Act (CMIA), sharing patient-specific information on social media platforms is a violation of federal and state privacy laws, and can have a devastating effect on you as an individual and UCSF.

• Act as if you were at work. Health care providers must maintain appropriate boundaries of the patient-physician relationship and follow professional ethical guidelines online and on social media just as they would in any other context.
• Perception is reality. Health care providers must recognize that actions online and content posted may negatively affect their reputations among patients and colleagues, may have consequences for their medical careers (particularly for health care professionals in training and medical students), and can undermine public trust in the medical profession.

Violations under the HIPAA Privacy Rule may incur penalties (which can result in fines of $100,000-$1,500,000 to the organization or the individual), and/or criminal penalties (which can result in fines from $50,000 to $250,000 and up to 1-10 years in prison). Violations of CMIA may result in fines of up to $250,000, in addition to criminal penalties.  Other consequences of violating HIPAA and/or CMIA may include lawsuits, the loss of a professional health license (medical, nursing, pharmacy, etc.) or employee discipline, leading up to termination.

Common examples of social media HIPAA and CMIA violations include:

• Posting gossip about a patient to even if the name is not disclosed.
• Sharing photographs, videos or any form of Protected Health Information without written consent from a patient.
• Soliciting health-related information, such as asking what type of medication someone is taking.
• Sharing seemingly innocent comments or pictures, such as a photo from a workplace lunch that happens to have visible patient information in someone’s hands or in the background.

Private groups and direct messages on social media are not secure forms of communication, and should not be used for communication with or about patients.

When in doubt, ask the Office of Communications.

Social Media Best Practices

• The Internet is a public (and permanent) space.  In most cases, everything you post online will be seen by a public audience.
• Expect that your posts and comments on others’ posts can and may be viewed by leadership, patients, prospective patients, and the media. Assume everyone is reading your words or seeing your photos, no matter how obscure or secure the site to which you are posting may seem. Remember that anyone can take a screenshot of your activities and distribute them beyond their intended audience.
• Be aware that you may be invoking a spotlight with your post. Make sure you are expressing views that you’d feel comfortable discussing or defending publicly. Be honest about who you are. If the conversation relates to UCSF, you should identify yourself as working for UCSF. Social media is all about transparency, and your affiliation with UCSF is public information. Don’t hide your identity or affiliations. It’s safer to assume that everyone will make that connection eventually and the outcome will be better for you if you disclose your affiliation rather than if you are “discovered”.
• If you wouldn’t say your comment in a public setting, don’t publish it on social media. If you have any doubt about a post, picture or comment, check with your compliance officer or a colleague before publishing.
• Identify the purpose of your social media channel, your target audience, the types of content you intend to share, and the overarching image you wish to convey, especially if you plan to use social media for professional development. A clear strategy will help you make decisions about the content you create. Before engaging in online platforms, become an observer. Listen to the conversations, view the content, and see what people are talking about. Many online forums have their own codes of conduct and rules of engagement. Becoming familiar with them shows respect for the practices of the forum and could help you engage more effectively with new communities.
• Add value to the discussion. Social media at its best is an exchange of helpful or interesting information through a two-way conversation. Positioning yourself as a source of interesting, helpful, and informative material is a great way to start developing relationships with other members of the community. Ask and answer questions, comment on others’ posts, and thank people when they comment positively on your content.
• Avoid arguments. Avoid posting materials or comments that may be seen as offensive, demeaning, inappropriate, threatening, or abusive. Respectfully withdraw from discussions that go off-topic or become profane.
• When in doubt, ask the Office of Communications.