Risks associated with government use of social media

Policy input on government use of social media

Government participation in social media serves three primary roles:

  1. Public outreach to deliver information and messages directly to citizens
  2. Encourage citizen involvement, interaction and feedback on government issues
  3. Provide leadership and public service announcements, particularly in times of crisis

Risks associated with social media

The General Services Administration (GSA), Small Business Administration (SBA) and Office of Management and Budget (OMB), Health and Human Services (HHS) and Centers for Disease Control and Prevention (CDC) have all been early pioneers of social media and micro-sites.  In some cases, these social media initiatives were implemented quickly and without policy guidance.  As more state, local and federal agencies quickly scramble to implement their social media campaigns, it is important to take recognize the risk factors and take appropriate precautions.

Legal risks and implications of government use of social media

Copy rights of video footage and photos uploaded by government representatives. Risks can be mitigated by following these standard operating procedures:

  • Agency source materials. Use only photos and videos produced by the federal government or contractors working directly on behalf of the federal government.
  • Obtain written copyrights. If copyrighted materials are use, be sure to get and maintain physical records of copy right licenses and honor any branding or labeling requirements specified in the copy right license.

Privacy rights of individuals who become friends, fans or followers of government agencies. Risks can be mitigated by following these standard operating procedures:

  • Account. Government representatives who set up accounts should use a general office e-mail account, agency or office name and general office phone number if possible.
  • Restrict to Find People and Follow People. Government policy regarding use of social networking sites should discourage agencies from following private citizen or commercial profiles from within their government social networking profile. While we cannot necessarily stop all people from being Friends, Fans or Following us, we should not click onto the profiles of our Friends, Fans and Followers.
  • Comments and Discussions. When possible, disallow comments and discussions on social profiles. Refrain from participating in dialogue and online discussions with social profile visitors.

Section 508 Compliance and accessibility rights for people with visual and hearing disabilities apply to social media sites as well. Risks can be mitigated by following these standard operating procedures:

  • Video captions and transcriptions. Embed captions within videos as part of the post production process. Provide transcripts of videos and attempt to include these transcripts on the social networking site. Maintain Section 508 compliant videos, captions and transcripts on the agency’s website and attempt to link back to the agency website from the social networking site.
  • Photo – alternative descriptions. Name the photo after the description before uploading it to the social networking site. Write text captions and descriptions when social networking site makes these form fields available.
  • PDFs. Work to make document compliant in source format before converting to a PDF. Use formatting such as headers when applicable. Embed hyperlinks within the anchor text rather than supplying the physical URL to the right of anchor text.

Brand management of agency seals, logos and color or style guides. Risks can be mitigated by following these standard operating procedures:

  • Profile Picture. Government profiles should upload the agency seal or logo as their picture. It is important to use the agency seal or logo to demonstrate authenticity.
  • Profile Design. Government profiles should change the background image to the agency seal or logo and unclick the tile background check box. Design colors should either reflect the colors of the agency or be conservative with white, background, black text, blue links, light gray sidebar and dark gray or black sidebar border. The reasons why colors and background are important are primarily for Section 508 compliance (web accessibility) and secondarily for professionalism and consistency with agency branding and style guide.

Records management as mandated by the Federal Records Act. All books, papers, maps, photographs, machine-readable materials, or other documentary materials, regardless of physical form or characteristics, made or received by an agency of the U.S. Government under Federal law or in connection with the transaction of public business must be preserved. Risks can be mitigated by following these standard operating procedures:

  • Duplicate, not create. Avoid creating new material on social networking sites. Instead, use existing material from existing websites or previously published documents.
  • Refrain from making comments.

Terms of Use – the ability for a government representative to accept the legal terms and conditions on behalf of the government as part of the process and requirements for creating an account. These risks can be mitigated by following these standard operating procedures:

  • Obtain legal review – copy the legal terms of use agreement and send to agency legal affairs office for review before accepting agreement on behalf of the U.S. government.
  • Check to see if parent organizations or central government organizations such as GSA or OMB have already developed direct agreements with the social networking site in question.

Popular Social Media Sites

The following section describes some of the most popular social media sites, effective government use of these sites and potential risks to mitigate.

Twitter

Description: Twitter is an online social networking site where members can post short updates and keep up with other members through online profiles or cell phone text messages.

Effective government use: Effective applications for government use of Twitter would be to re-broadcast the agency’s blog headlines, news releases, testimonies, statements, public service announcements, accomplishments, job announcements and fact sheets. The emergency management community uses Twitter for local real-time updates and short nationwide announcements. Other uses of Twitter may be to alert citizens of emergency broadcasts, epidemics, recalls, hazardous materials incidents, national incidents, terrorists’ threats and natural disasters.  RSS feeds can automate the delivery of news releases and updates to Twitter accounts.

Risks: Legal implications of Twitter relate primarily to the privacy of members that follow government Twitter accounts and the appearance of commercial endorsement. These risks can be mitigated by restricting Settings and use of Follow ability.  It is also possible for any person with a Twitter account to impersonate a government agency in an effort to mislead the public.  It is important for government agencies to use their official seal as their logo and include the URL to their .gov website in their Twitter profile.

YouTube

Description: YouTube is an online social networking site where members can post videos, comment on videos, provide video responses, mark videos as favorites and subscribe to video channels.

Effective government use: Effective applications for government use of YouTube would agency sponsored public service announcements, recruiting videos, licensed broadcasts, animated instructions, guides or user’s manuals and agency produced B-roll (supplemental or alternate footage available to be intercut with the main shot in an interview or documentary, footage provided free of charge to broadcast news organizations as a means of gaining free publicity). YouTube has a distinct following of segmented demographic audiences that regularly spend multiple hours per day on the site and login frequently. YouTube has a captive audience and provides advertising opportunities.

Risks: YouTube keeps track of personally identifiable information associated with members and that information could be used to monitor member activities.  Government agencies should be sensitive to privacy issues.  Government agencies should also be careful not to upload copyrighted materials to their official government YouTube channel.  Agencies should also identify their channel as an official government channel because YouTube has a separate Terms of Use policy for government accounts.  Agencies should also ensure that they deploy closed captions or transcripts of their videos to comply with Section 508 rules for accessibility.

Facebook

Description: Facebook is an online social networking site where members can create videos, update their status, create photo albums, post photos, post videos, write on their wall, instant message with other members, send internal e-mail to other members, find friends, add friends, become fans of groups and organizations. Facebook integrates the best features from other sites like Twitter, YouTube, Flickr and MySpace.

Effective government use: Effective applications for government use of Facebook would agency sponsored public outreach programs that target segmented audiences, public service announcements, agency information, emergency broadcasts and other public affairs activities. Agencies would use Facebook primarily because it has a loyal audience with frequent logins that are often multiple times per day. Members often spend hours on Facebook every day. Facebook is a captive audience with targeted demographics and advertising opportunities.

Risks: Current Facebook Terms of Use implies that all content uploaded to Facebook becomes the property of Facebook.  Agencies should be cautious and sensitive to the content that is uploaded.  Significant sensitive and personally identifiable information is maintained on Facebook and easily accessible.  It is important to be sensitive to privacy issues.  People who create Facebook pages on behalf of the government should not put personal information in their government profile.  Agencies should also ensure that copyrighted material, such as photos and videos, are not uploaded to their official Facebook profile.  Agencies should use their official seal and a link back to their .gov website.