250124Paper3PersonalUseofSocialMediaPolicy0701

Cairngorms Nation­al Park Paper 3 Resources Com­mit­tee 24 Janu­ary 2025 Pàirc Nàiseanta a’ Mhon­aidh Ruaidh Page 1 of 6

For dis­cus­sion Title: Per­son­al use of social media policy Pre­pared by: Brenna Jessie, Digit­al Com­mu­nic­a­tions Manager

Intro­duc­tion and scope

1. This policy sets out expect­a­tions for the per­son­al use of social media by staff and board mem­bers at the Cairngorms Nation­al Park Author­ity as mem­bers of a pub­lic sec­tor organ­isa­tion in Scot­land. It seeks to provide clar­ity on the bound­ary between online and off­line activ­ity, and to sup­port social media users to help bal­ance their online pres­ence with their role as an employ­ee / board mem­ber of the organisation.
2. Social media is an import­ant and valu­able part of many people’s lives, offer­ing oppor­tun­it­ies for con­nec­tion, learn­ing and engage­ment. How­ever, there are inev­it­ably per­son­al and organ­isa­tion­al risks asso­ci­ated with social media use, includ­ing the poten­tial to put an opin­ion or com­ment in writ­ing per­man­ently into the pub­lic domain. Staff and board mem­bers should be aware of this in com­ply­ing with the wider policy and stand­ards expect­a­tions of their roles.
3. Activ­ity with­in social media plat­forms brings wider con­sid­er­a­tions of wheth­er staff or board mem­bers may be per­ceived to be act­ing in their per­son­al or Park Author­ity capa­cit­ies. A key con­sid­er­a­tion here is about the per­cep­tion of oth­ers. We may not always be able to fully con­trol that per­cep­tion, nor under­stand how oth­ers come to devel­op their per­cep­tion of us as act­ing either as private indi­vidu­als or as mem­bers of the Park Author­ity. You should be mind­ful, there­fore, that your per­cep­tion of when you are car­ry­ing out offi­cial busi­ness and when you are act­ing privately may be dif­fer­ent to how it is viewed by a mem­ber of the pub­lic. This policy doc­u­ment sup­ports staff and board mem­bers in their use of social media and com­ply­ing with wider expect­a­tions of staff and board conduct.
4. This policy applies to use of social media both dur­ing and out with work­ing hours and applies regard­less of wheth­er accounts are accessed using Park Author­ity equip­ment or not.

Cairngorms Nation­al Park Paper 3 Resources Com­mit­tee 24 Janu­ary 2025 Pàirc Nàiseanta a’ Mhon­aidh Ruaidh Page 2 of 6

1. Please note, any alleg­a­tions of mis­use of social media, or breaches of this policy by staff will be invest­ig­ated by the HR team and could lead to dis­cip­lin­ary action. Any issues arising from board mem­bers’ use of social media is covered by the pro­vi­sions of the Park Authority’s code of con­duct, sup­por­ted by the guid­ance issued by the Stand­ards Com­mis­sion for Scot­land, and will be man­aged accord­ing to rel­ev­ant pro­ced­ures for man­aging com­plaints made on board mem­bers’ activity.
2. All doc­u­ments referred to through­out this policy are linked to in the bot­tom of the document.

Man­aging per­son­al social media accounts

1. Staff and board mem­bers are entitled to pri­vacy and to their exer­cise of free speech when express­ing their per­son­al views, and the organ­isa­tion sup­ports per­son­al social media use for those who wish to do so. Equally, there is an expect­a­tion that – in act­ing either as mem­bers of staff or as a board mem­ber – you will col­lect­ively sup­port and uphold the decisions and sup­port agreed dir­ec­tion and work of the organisation.
2. The Park Author­ity expects staff and board mem­bers to take respons­ib­il­ity for man­aging their online pres­ence to ensure that it does not risk con­flict­ing with the work, policies or repu­ta­tion of the organ­isa­tion. This applies regard­less of wheth­er social media accounts are pub­lic or private.
3. Any requests received through social media, for example media or inform­a­tion requests, should be routed through stand­ard intern­al chan­nels and not respon­ded to through social media.
4. As mem­bers of a Scot­tish Gov­ern­ment non-depart­ment­al pub­lic body, inter­ac­tions online and in per­son should align with the organ­isa­tion­al code of con­duct and principles.
5. Park Author­ity staff and board mem­bers are import­ant and influ­en­tial mes­sen­gers with­in their own com­munit­ies; shar­ing social media posts from the Park Author­ity feeds is there­fore wel­come, but not man­dat­ory. The Park Author­ity has an organ­isa­tion­al policy of a right to dis­con­nect and so there is no expect­a­tion that staff engage in work related con­ver­sa­tions on per­son­al social media. It’s worthwhile

Cairngorms Nation­al Park Paper 3 Resources Com­mit­tee 24 Janu­ary 2025 Pàirc Nàiseanta a’ Mhon­aidh Ruaidh Page 3 of 6

remem­ber­ing that shar­ing Park Author­ity posts may indir­ectly link staff and board mem­bers to their pos­i­tion in rela­tion to the organ­isa­tion, so indi­vidu­als should con­sider wheth­er this is some­thing that they are happy with.

1. Regard­less of wheth­er staff and board mem­bers state their place of work or not, social media users can often eas­ily be traced to their employ­ers. This is par­tic­u­larly the case in small, rur­al com­munit­ies, where staff and board mem­bers may have a high pro­file and through that clear links to the Park Authority.
2. It can be dif­fi­cult for people to sep­ar­ate their own per­cep­tion of you as an indi­vidu­al and as someone asso­ci­ated with the Park Author­ity, and so staff and board mem­bers have a duty to con­sider how their per­son­al online activ­ity reflects on the organ­isa­tion. For example, com­ments made about the Scot­tish Government’s approach to afford­able hous­ing, a plan­ning applic­a­tion, fire man­age­ment with­in the Nation­al Park or spe­cies rein­tro­duc­tion may be inter­preted as an organ­isa­tion­al pos­i­tion and lead to com­plaints, quer­ies or media coverage.
3. Anoth­er example could be where a board mem­ber, who includes being on the board of their pub­lic body in their X / Twit­ter pro­file, retweets a post which con­tains a descrip­tion of the ser­vice provided by their pub­lic body as being sub­stand­ard and unac­cept­ably poor. While the post in ques­tion was not writ­ten by the mem­ber, the fact that they have chosen to retweet in cir­cum­stances where they are iden­ti­fi­able as a mem­ber, could be seen as being sup­port­ive of the cri­ti­cism in their capa­city as such.
4. The con­sid­er­a­tion of wheth­er you will be per­ceived on social media as act­ing as a rep­res­ent­at­ive, board mem­ber or employ­ee of the Park Author­ity when inter­act­ing on social media is covered by the Stand­ards Commission’s guid­ance, which gives help­ful advice for both staff and mem­bers. Their guid­ance states: a) ​“It may be help­ful, in cer­tain cir­cum­stances, to state that you are express­ing your own per­son­al view, rather than the view of your pub­lic body. You should, how­ever, always be mind­ful of how you could reas­on­ably be per­ceived when doing so and wheth­er your com­ments could object­ively be con­sidered as reflect­ing the views of your pub­lic body, regard­less of any state­ment about it being a per­son­al com­ment. It can be very dif­fi­cult to per­suade people that you can take a dif­fer­ent view, or even have an open mind, in your capa­city as a mem­ber of a pub­lic body from a view you may have expressed in your per­son­al capa­city. This is par­tic­u­larly per­tin­ent in respect of using social media, or

Cairngorms Nation­al Park Paper 3 Resources Com­mit­tee 24 Janu­ary 2025 Pàirc Nàiseanta a’ Mhon­aidh Ruaidh Page 4 of 6

com­ment­ing in the press, where the sep­ar­a­tion of pub­lic and private com­ments may be unclear to someone read­ing them, and where inform­a­tion about your mem­ber­ship of the pub­lic body may be read­ily avail­able online or from dif­fer­ent sources (includ­ing your pub­lic body’s website).”

1. Staff and board mem­bers using social media must ensure that their com­ments or inter­ac­tions online do not overtly or inad­vert­ently reveal private, con­fid­en­tial or sens­it­ive inform­a­tion gained through work with the Park Authority.
2. There is a per­man­ence to any mater­i­al shared or inter­ac­ted with online, even if it is deleted, and a poten­tial for con­tent to be taken and shared without con­text, or to suit spe­cif­ic agendas.
3. It is the respons­ib­il­ity of staff and board mem­bers to check their pri­vacy set­tings to ensure that they are aware of and com­fort­able with who can access con­tent pos­ted, shared, com­men­ted on, saved or inter­ac­ted with in any way. How­ever, even the most strin­gent of pri­vacy set­tings do not entirely remove the risk of posts being shared bey­ond their inten­ded audience.
4. If staff and board mem­bers receive any media requests through social media, or enquir­ies from the pub­lic related to Park Author­ity work, these should be flagged urgently with the Com­mu­nic­a­tions team pri­or to any response.

Min­im­ising risk on social media – guidance

1. To sup­port staff in using social media, whilst man­aging the risks asso­ci­ated both to the organ­isa­tion and them­selves, we’ve developed some do’s and don’ts. If in any doubt, the Com­mu­nic­a­tions team are happy to advise and sup­port in this area.
2. Do: a) Share Park Author­ity con­tent from the organ­isa­tion­al social media chan­nels and web­site if you would like to. b) Be mind­ful of the staff or board code of con­duct and your respons­ib­il­it­ies as an employ­ee / board mem­ber of a pub­lic body. c) Keep per­son­al and pro­fes­sion­al accounts sep­ar­ate, and do not cre­ate mater­i­als using organ­isa­tion­al logos or brand assets without per­mis­sion. d) Include a line in your social media bio that states ​‘Views expressed are my own’. Be aware that it is not guar­an­teed that this will be seen, can­not be guar­an­teed to

Cairngorms Nation­al Park Paper 3 Resources Com­mit­tee 24 Janu­ary 2025 Pàirc Nàiseanta a’ Mhon­aidh Ruaidh Page 5 of 6

change oth­ers’ per­cep­tions of you as a mem­ber of staff or board, and does not remove the need to act in line with the policy. e) Ensure that any com­ment you make that is asso­ci­ated with Park Author­ity work is in line with the organisation’s key mes­sages, sup­port­ive of the decisions taken and / or dir­ec­tion of agreed activ­ity and only con­tains inform­a­tion that is already in the pub­lic domain. f) Be aware that tak­ing pos­i­tions, even on your private account, that con­tra­dict the pos­i­tion or val­ues of the Park Author­ity could cause repu­ta­tion­al harm and lead to invest­ig­a­tion / dis­cip­lin­ary action. g) Speak to the Com­mu­nic­a­tions team for advice and guid­ance before set­ting up any account that is spe­cific­ally ded­ic­ated to talk­ing about your work. h) Route any inform­a­tion or media requests through stand­ard intern­al chan­nels rather than respond­ing on social media i) Think before you post; con­sider wheth­er you would say this in per­son and bear in mind that con­tent can be screen­shot­ted and shared in per­petu­ity, even after it is deleted. j) Flag any inflamed debates or con­ver­sa­tions about the Park Author­ity to the Com­mu­nic­a­tions team as soon as pos­sible through work con­tact details, rather than per­son­al con­tact details, or the communications@​cairngorms.​co.​uk inbox. k) Check and main­tain your pri­vacy set­tings so that you are aware of who can see your con­tent. I) Ensure you have com­plied with the law includ­ing defam­a­tion, con­tempt of court, copy­right, data pro­tec­tion, employ­ment and equal­it­ies or har­ass­ment provisions.

1. Don’t: a) Assume no one can see your con­tent because you only have a small num­ber of con­tacts. b) Enter debates on sens­it­ive top­ics or respond to cri­ti­cism about the Park Author­ity, even if you’re dir­ectly tagged, unless you are abso­lutely con­fid­ent that your response is in line with the organ­isa­tion­al pos­i­tion, that you have con­sidered all pos­sible sens­it­iv­it­ies, and that this will not risk any neg­at­ive reper­cus­sions. c) Com­ment on or share views on issues that could reflect neg­at­ively on / under­mine the repu­ta­tion of the organ­isa­tion, includ­ing issues like the clos­ure of a ser­vice, a loc­al fund­ing decision or wider polit­ic­al con­ver­sa­tions. d) Engage in pro­trac­ted con­ver­sa­tions or debates about the work of the Park Author­ity on your per­son­al account, even if dir­ectly approached. Instead, speak to the Com­mu­nic­a­tions team for sup­port and advice.

Cairngorms Nation­al Park Paper 3 Resources Com­mit­tee 24 Janu­ary 2025 Pàirc Nàiseanta a’ Mhon­aidh Ruaidh Page 6 of 6

e) Share inform­a­tion about the Park Author­ity or know­ledge that is private, con­fid­en­tial or sens­it­ive, gained through your inter­ac­tion with the organ­isa­tion. This includes detail about indi­vidu­al staff or board mem­bers involved with mak­ing any decision.

1. If you become aware of a col­league or board mem­ber of the Park Author­ity enga­ging in online beha­viour which you feel con­tra­dicts this policy or the staff code of con­duct, this can be raised with your line man­ager and / or HR.

Asso­ci­ated policies and guid­ance a) Staff code of con­duct (Appendix four of hand­book) b) Board code of con­duct c) Register of interests policy d) Dig­nity at work policy e) Pri­vacy set­tings online – link to resource f) Stand­ards Com­mis­sion advice note for mem­bers g) Stand­ards Com­mis­sion mod­el code of con­duct guid­ance h) Brand and tone of voice guidelines

Brenna Jessie 09 Decem­ber 2024 brennajessie@​cairngorms.​co.​uk