TUSDM Policy on Social Media Use

I. Purpose and Scope:

Social media services (e.g., Facebook, Twitter, and Instagram) are an easy and effective way to share user-generated content. Unfortunately, the improper use of such services can result in unintended negative consequences. The purpose of this policy is to establish social media rules and recommended best practices that properly represent, and protect, Tufts University School of Dental Medicine (TUSDM) and its interests. Make note that this policy identifies some, but not all, of the possible risks associated with social media use.
This policy is applicable to all TUSDM Workforce members while at the school, at a school-related event or activity, or conducting school-related business.

II. Policy Statement:

Using social media services can potentially pose significant risks to the privacy rights of TUSDM patients, students, residents, staff, faculty, or vendors, and to TUSDM’s reputation.
To minimize such risks, TUSDM is committed to ensuring the confidentiality of electronic Protected Health Information (ePHI) and electronic Protected Personal Information (ePPI).
As a result, TUSDM acknowledges that all existing federal and commonwealth laws and regulations concerning ePHI and ePPI apply to social media, too.

IV. General Rules:

Do’s.
1. Do get your electronic devices (e.g., cellphone, tablet, laptop) encrypted. This is required for all at TUSDM that are using their devices to conduct Tufts University business.
2. Do install security software on your electronic devices to protect against viruses, spyware, and other malicious software, and upgrade this software regularly.
3. Do get permission before posting content containing anyone’s image and/or information. Make sure such content doesn’t violate any HIPAA regulations. If in doubt, don’t post, and consult with applicable TUSDM faculty or staff.
4. If you choose to post on social media, it must be on a sanctioned TUSDM social media with the permission from faculty. Posting on personal social media sites is not allowed.
5. Do remember that all TUSDM electronic communication systems, and the content they contain, are the property of Tufts University.
  1. Except for content protected by HIPAA, all TUSDM Workforce members must have no expectation of privacy, in any format, concerning any content transmitted to, received by, stored on, or printed from these systems.
  2. TUSDM has the right to monitor all use of these systems, including use pertaining to social media.
  3. TUSDM Workforce members consent to such monitoring as part of their employment and/or enrollment at TUSDM, therefore, do not use TUSDM systems to transmit, receive, store, or print any content you wish to keep private.
  4. As a result, TUSDM has the right to store or delete such content without giving prior notice.
Don'ts.
1. Don’t speak on behalf of TUSDM unless you have been explicitly authorized to do so.
2. Don’t impersonate anyone who is authorized to speak on behalf of TUSDM.
3. Don’t post or promote fabricated content about TUSDM, whether positive or negative.
4. Don’t post or promote confidential information about TUSDM, its patients, students, residents, staff, faculty, vendors, or yourself.
5. Don’t acknowledge that any patient has received, is receiving, or will receive dental care at TUSDM.
6. Don’t give dental advice or make dental diagnoses over social media. (If a current or potential patient asks any dental-related questions, strongly encourage him or her to make an appointment with a TUSDM clinic.)
7. Don’t use your Tufts e-mail address for social media accounts.
8. Don’t use TUSDM’s name to promote or endorse any product, service, cause, or political party/candidate.
9. Don’t engage in any conduct that is unacceptable in the TUSDM community.
10. Don’t violate any TUSDM network-use policies.
Recommended Best Practices.
1. Remember that social media services are open to a worldwide audience. There’s no such thing as a private social media service, therefore, use good judgement when you’re on social media (i.e., only post or promote content you would share in a public setting, now or in the future).
2. Remember that you are responsible for any content you post online. This includes content posted to your account and to the accounts and sites of others. You may be held responsible for content considered libel, proprietary information, or copyright infringement.
3. Read the privacy and caching statements of any social media service you may use. Remember that any content you post or promote will remain accessible until you have completed a prescribed process for removing content from the caching technology of one or more search engines.
4. Consider how much personal information you might want to share on social media and how that information could be used by others against you or TUSDM (e.g., home address, telephone number, etc.).
5. Set your privacy settings to help control who can look at your social media account. Remember that you cannot fully limit access nor control what someone else might share with others.
6. Monitor comments posted on your account. Set your privacy settings so you can review and approve comments before they are displayed.
7. Consider any potential Conflict of Interest (COI) issues before establishing an online relationship with TUSDM patients, students, residents, staff, faculty, or vendors and the nature and implications of such social interaction. This means never posting or promoting confidential or proprietary content about TUSDM patients, students, residents, staff, faculty, or vendors. And always comply with HIPAA regulations to ensure patient privacy, whether using social media for personal or professional use.

V. Policy Compliance Monitoring and Enforcement:

All TUSDM workforce members are responsible for ensuring that individuals are aware of and comply with this policy.

VI. Potential Disciplinary Actions and Sanctions:

TUSDM Workforce members who do not comply with this policy may be required to receive additional training and/or be referred to the appropriate authority for potential disciplinary action, e.g.:
1. TUSDM students and residents via the Ethics, Professionalism, and Citizenship Committee.
2. TUSDM staff via Human Resources.
3. TUSDM faculty via the Compliance Committee or the Risk Management, Safety, and Infection Control Committee.

VIII. Approval and Review Cycle:

This policy will be subject to annual review, revision, and approval by the TUSDM Compliance Committee.

Attachments:

Guidelines for Employees’ Personal Use of Social Media