Vanguard Social Media Policy

Purpose

The purposes of this Social Media Policy is to provide employees, contractors, and volunteers of Vanguard Health Systems (“Vanguard”) with the necessary requirements for participation in social media, including Vanguard’s hosted social media and non-Vanguard hosted social media sites.

Scope/Coverage

This Social Media Policy applies to Vanguard, its subsidiaries and affiliates, physician and non-physician employees, contractors, and volunteers. It also covers all users of Vanguard’s or any hospital’s computer systems. Vanguard will not construe or apply this Policy in a manner that interferes with employee rights under the National Labor Relations Act.

Background and Philosophy:

The emerging availability of social networks represents a powerful new tool for communications, marketing, work collaboration and interaction. Vanguard is built around innovation in the delivery of health and health care. As an innovator, Vanguard encourages open exchange among us, with our patients and between our physicians and staff in order to inspire change and motivate invention.

To ensure that Vanguard and its employees adhere to their ethical and legal obligations, employees are required to comply with Vanguard’s Social Media Policy. The intent of this Policy is not to restrict the flow of useful and appropriate information, but to minimize the risk to Vanguard and its employees.

Because these tools are new, it is important that we all share an understanding of the basic “rules of the road” for their use, the manners and mores of social media sites and some special considerations based on our role as a healthcare provider.

Rule 1 – always protect patient privacy. Never reveal any information that would directly or indirectly identify a patient. Always abide by all policies, rules and regulations.

Rule 2 –think of the consequences. Your comments on a social media site become permanent and an indisputable record of what you wrote. And your comments can be instantaneously sent to anyone. There is no right to privacy once you have put information into a social media network. It is available for Vanguard to see and others such as your friends, family, coworkers and even your mother or father.

Rule 5 – use a personal email address (not your vanguardhealth.com or hospital email address) as your means of identification or communication with respect to the social media site unless you are engaging in professional activity on behalf of Vanguard. Just as you would not use Vanguard letterhead for a letter expressing your personal views, you should not use your Vanguard email address for personal social media purposes.

Rule 6 – respect all copyright, privacy, fair use and financial disclosure laws.

Rule 7 - alert Vanguard Communications Office if someone from the media or press contacts you about any postings or statements you make related to Vanguard in any way.

Rule 8 – be mindful that inappropriate, unethical or illegal personal behavior on the Internet, whether you identify yourself as Vanguard staff or not, can negatively affect your career. A list of prohibited conduct is defined in this Policy.

Rule 9 – be polite. When communicating through new media imagine that you are having a face-to-face conversation.

Rule 10 – this Social Media Policy will not be construed or applied in a manner that interferes with employees federally protected rights under the National Labor Relations Act.

Definition:

Social media is a class of new media characterized by voluntary participation in networks of like-minded individuals with social and economic value. Interactions are enabled by Internet and mobile technology and allow individuals to publish and distribute information to networks or reproduce and redistribute information. Communication is interactive and democratic, non-hierarchical and not subject to editorial or expert control.

Examples: Facebook, Google+, YouTube, LinkedIn, Twitter, Spoke, Plaxo, MySpace, Flickr, Second Life, Yelp, Foursquare and Skype.

Corporate Presence on Open Social Media:

Like any other medium of publication carrying the Vanguard name, any social media presentation representing Vanguard or any of its corporate affiliates must be properly approved through the communications officer who oversees either the market, the hospital/facility or corporate communications.

In addition, any content produced for corporate sites must identify a person who is the “content owner” and is responsible for maintaining and refreshing the content, reviewing comments placed on the site by other users and responding appropriately to comments which include removing offensive or inflammatory content.

Any social media presence that carries Vanguard’s corporate identification and is presented as representing Vanguard’s corporate opinion, position or message must be approved or created through the corporate or market communications systems.

Staff Participation in Professional Social Networks:

Certain social media networks are developed for the express purpose of sharing information, developing skills and exchanging non-competitive information about best-practices among professionals with similar responsibilities. Participation in closed social networks of this sort are both permitted and encouraged. Explicit permission is not required to participate.

However, there are important limitations that any participant in professional social networks must be aware of and responsible for. These limitations are described in this policy and outlined below under the heading “Prohibited Subjects/Actions on Social Media.” Keep in mind that any contribution you make to these closed professional networks are not guaranteed to remain within those networks, so knowing and trusting your colleagues is important. In these networks you are able to discuss Vanguard practices and policies that are not confidential and speak as a member of the staff at Vanguard within your scope of work. Examples: Sermo, LinkedIn, AllNurses and NurseConnect.

Staff Participation in General Social Media:

The following guidelines are intended to help staff understand when they can and cannot use their affiliation with Vanguard and their professional role in general social media exchanges. You may identify your professional role at Vanguard, your work location and general descriptions of the corporation or any of its affiliate organizations, in the same manner as if you were including these in your professional resume. However, if you identify Vanguard as your employer, you must include a disclaimer making clear that any opinions you express are your own. For example, if you identify yourself on Facebook as an employee of Vanguard, use a disclaimer such as “My opinions and the views expressed on this site are my own and do not reflect the views of Vanguard.”

As described above, there are important limitations that any participant in professional social networks must be aware of and responsible for. These limitations are described in this policy and outlined below under the heading “Prohibited Subjects/Actions on Social Media.”

Staff Participation in Health or Disease-Related Social Networks:

One of the most important innovations in social media has been the development of communities comprising individuals who share an interest in a particular disease. These sites gather people who are suffering with the disease, their family and individuals who offer services and care. In their simplest form, they are chat rooms for people who seek advice or wish to share advice, to find empathy through others facing similar circumstances and to share information about how to cope.

Generally speaking, descriptions of personal experiences at work are permissible with important limitations. The limitations set for all health care professionals under federal and state laws, rules and regulations, including the Health Insurance Portability and Accountability Act (HIPAA) about revealing health information must always be strictly adhered to. Revealing protected health information in social media is punishable by fine and even imprisonment by the federal government and dismissal by Vanguard. Because information shared over social media is so easily distributed, heightened caution must be exercised.

Keep in mind that health information can be linked to an individual without ever mentioning the person’s name. So simply limiting a discussion to information about an anonymous person may not be sufficient to protect them from a breach of their patient confidentiality and it is everyone’s job to absolutely protect the right to confidentiality of all of our patients.

However, there are important limitations that any participant in professional social networks must be aware of and responsible for. These limitations are described in this policy and outlined below under the heading “Prohibited Subjects/Actions on Social Media.”

Staff Access to Social Networking Tools at Work:

Like the telephone, e-mail and the internet, social media are tools for communication. Like these other tools of communication, social media can be used for both business and personal purposes. In the workplace, staff is encouraged to use social media tools for business purposes. These new social media tools have proven to be effective ways to both conduct business and to market products and services. Each market of Vanguard shall determine the level of staff access to social networking tools at work. The level of staff access at each market will be reviewed on a continuing basis.

Vanguard believes in providing these sorts of productivity and reach-enhancing tools to its staff and expects them to use these tools responsibly and within the limits of standard business conduct. In much the same way as Vanguard allows and expects some use of its telephones, computers and e-mail for personal use, the same level of tolerance within reason should be applied to social media. Excessive personal use of any business tool is not appropriate and violates Vanguard policy.

Prohibited Subjects/Actions on Social Media

In order to maintain Vanguard’s reputation and legal standing, the following actions and subjects may not be discussed by employees in any form of social media:

● Health information or information of any kind relating to a patient;
● Health information or information of any kind relating to a Vanguard employee or contractor;
● Information about patient safety errors and/or serious medical events;
● Disparagement of any patient, family member or friend of a patient;
● Vanguard confidential or proprietary information;
● Confidential or proprietary information of clients, partners, vendors, or
suppliers;
● Vanguard intellectual property;
● Disparagement of Vanguard’s or competitors’ services, products, executive leadership, employees, strategy, and business prospects;
● Explicit sexual references;
● Reference to illegal drugs or illegal possession of narcotics;
● Obscenity or profanity;
● Disparagement of any race, religion, gender, sexual orientation, age, disability, genetic information, or national origin;
● Practice of medicine or offering clinical advice without Vanguard authorization (If you have any questions about whether you are offering clinical advice, please contact your chief medical officer or the legal department);
● Referral of any individual to a physician, especially those affiliated with the Vanguard (If you have any questions about whether something you discuss could be treated as a referral, please contact a member of the legal department);
● Use of Copyrighted information without appropriate permission or identification, as required;
● Material and non-public information which can be considered as engaging in insider trading if disclosed to others; and
● Information which can be considered as violating state and federal anti-trust laws.

If you have any questions about these prohibited activities and discussions, please contact the communications office or the legal department.

Employees who violate Vanguard’s Social Media Policy may face disciplinary action, up to and including termination.

Enforcement of Social Media Policy

The corporate communications office and the communications office or their designees in each market will periodically conduct automated searches and review information and postings on social media sites to gauge level of activity, appropriate use of Vanguard’s name and image, and conduct of Vanguard employees. No action will be taken by Vanguard personnel that can be construed or viewed as illegal surveillance of employees’ exercise of their federally protected rights under the National Labor Relations Act.