Social Media Policy Questions for Local Governments to Answer
Editor's note: This blog was edited to add that any social media policies drafted by a local government agency should be vetted by an agency attorney or legal counsel.
Facebook launched in 2004 and became available to the general public in 2006. While it certainly was not the first social media platform, the degree to which it altered the digital landscape and how we reach out to each other cannot be overstated. By 2009, MRSC was regularly receiving inquiries from local governments looking to adopt social media policies — to either limit or prohibit its use or to capitalize on the promise of outreach.
Over the years we have shared numerous sample policies, given insight on the elements of a good social media policy, and even published an entire webpage dedicated to Social Media Policies. As we look back at 20 years of widespread social media usage, I thought it was a good time for folks to revisit their policies and see if they can answer these nine important questions.
Nine Questions to Ask About Your Social Media Policies
1. Is your policy guided by a communication goal?
Social media can be used to push important information out to the public, but it can also be used to recruit employees, solicit public input, and foster a sense of community. Clearly defined communication goals makes it easier to select which social media platform best serves your needs. Goals can also guide content and usage norms. Consider this resource from the International City/County Management Association: The Four Pillars of Ethical Digital Engagement.
2. Which social media platforms are approved for use?
Top social media platforms used by local governments include Facebook, Twitter, YouTube, Nextdoor, Nixle, and Instagram. This list will likely change, and your agency will need to evolve if it wants to continue to digitally connect with constituents. Your agency should have a policy to approve new agency accounts and new platforms as necessary and to review or audit existing accounts to ensure they are still serving the agency’s needs. For example, the City of Yakima’s policy lists approved social media sites and requires any additional sites be approved by the city’s Communications Director.
3. Whose job is it to manage content?
Public outreach is a vital part of local government, and using social media to reach the public should not be an afterthought. Social media management and coordination should be part of the job description (and actual work duties) of identified employees. Here is an sample Social Media Intern job description from the City of Renton.
Additionally, a plan should be in place to funnel important information to the correct staffperson to ensure it reaches the public in a timely manner. For example, in King County, only “authorized agents” may post content to sites.
4. Are you retaining posts (and comments) via a separate technology?
None of the social media platforms guarantee that your posts will remain on their site for any length of time or otherwise be backed-up in the case of a server failure. Your agency cannot rely on the platforms to meet your records retention obligations and will need to use another technology that captures and stores social media posts and comments, such as ArchiveSocial, PageFreezer, and Smarsh. Outside retention technologies have the added benefit of making searching social media content easier for responding to public records requests. See this Clerk’s Guide to Social Media Record Keeping created by ArchiveSocial in partnership with the International Institute of Municipal Clerks. Also see MRSC’s PRA and Records Management Technology Guide.
5. Who has username and password control of the account?
Agency accounts should be created in a manner that allows multiple people to access and administer an account. Agency accounts are the property of the agency. Login information should be known to several people and accounts should not be created with email accounts assigned to a single person. When Sally Smith retires next month and her email address is deactivated, you may find yourself locked out of any social media accounts where she used her email address to sign up. Email address that are unlikely to be deactivated should be used, such as “CityClerk@city.gov” or “CountyDepartmentName@county.wa.us.” See this resource: Best Practices for State Agency Social Media Usage in North Carolina. Also, see the King County Social Media Handbook (2020).
6. Have you established rules of decorum for comments?
If your agency allows commenting on its social media posts, there should be clear guidelines consistent with the platform’s rules that ensures inappropriate content is removed (but still retained for records retention obligations). Those seeking more information or records should be directed to reach out to the appropriate contact person. For example, see the City of Seattle's Online Posted Content and Commentary Policy or MRSC’s Social Media Comments Policy. A note of warning — your comment moderation policy needs to be vetted by your agency attorney to ensure it does not run afoul of First Amendment protections.
7. Does your policy focus on accessibility? Are your images accompanied by a description?
To assist with the accessibility of social media for persons who are blind or visually impaired, any images should be accompanied by a description. If a person has access to a screen reader, they will still benefit from the content that is being communicated via a picture. Image descriptions are also useful for people with visual processing or learning differences. Your policies should be reviewed with a lens to ensure the content is being managed in a manner that increases accessibility. See this resource from the Perkins School for the Blind: How to Write Alt Text and Image Descriptions.
8. Does your policy address the use of personal social media accounts?
While being sensitive to First Amendment protections, public employees still need to know that their activity on social media may reflect back on the agency and their employment. Employees should be warned that if they discuss agency business on their personal accounts, it may cause their posts to be considered public records subject to disclosure. We highlight a few examples on our Social Media Policies webpage, including the City of Bothell. See also this blog: Private Lives of Public Employees: The PRA Implications of Working for the Government.
9. Are your governing bodies and citizen committees trained on social media usage?
There are significant public records and open public meeting concerns when members of governing bodies and their committees engage on social media. Agency training and policies should address posting and commenting on posts, as well as potential records retention issues that apply both to any official social media accounts and to the members’ personal social media accounts.
Some Things Change, Some Stay the Same
So, what was our response to that first request in 2009 for sample social media polices?
Cities haven’t updated their policies as fast as new applications become available or perhaps they just haven’t shared them with us. … If you find some examples or develop a new policy, please send us an electronic copy or link so we can add it to our resources for future reference.
As technology continues to change and local policies are updated, our request still stands — please send MRSC a copy so we can add it to our resources!
MRSC is a private nonprofit organization serving local governments in Washington State. Eligible government agencies in Washington State may use our free, one-on-one Ask MRSC service to get answers to legal, policy, or financial questions.