1.0 Purpose & Goals Description

The advancement of telecommunication technology, proliferation of Social Media platforms, and the Internet, have profoundly changed the way in which individuals and organizations communicate, exchange information and ideas. However, Social Media and Smart Phone technology tools also bring an increased threat to the privacy of patients, risks for sharing of proprietary corporate information, and employee communication; both innocent and intended. St. Joseph’s Healthcare recognizes the importance of Social Media platforms and online communities such as Facebook, LinkedIn, YouTube and Twitter, and their importance in professional development, information sharing and education.

St. Joseph’s Healthcare recognizes our responsibility to develop policies and procedures in order to minimize the risk of unauthorized and inappropriate use of information technology and Social Media, as well as create a collaborative and supportive environment for employees to engage in Social Media. The purpose of this policy is to set out a direction and requirements for employees, volunteers, learners, researchers and physicians of St. Joseph’s Healthcare Hamilton participating in the social media realm, and representing oneself and the organization online.

1.2 The scope of this policy includes all departments within SJHH and the St. Joseph’s Healthcare Foundation [SJHF] and including all employees, volunteers, physicians, researchers, contractors and learners. These restrictions are intended to ensure compliance with legal and regulatory restrictions and privacy of personal information, confidentiality, breach in patient privacy and communication system policy.

1.3 The purpose of this policy is to provide St. Joseph’s Healthcare employees with requirements for participation in social media, including St. Joseph’s Healthcare Hamilton and St. Joseph’s Healthcare Foundation hosted social media, and in affiliation is known, identified or presumed.

1.4 To clearly outline the privacy, confidentiality, legal and ethical issues that all employees, physicians and volunteers have in regard to the use of social media.

2.0 Definitions

2.1 For the purpose of this policy, “Social media” refers to all online (social media or web 2.0) tools used to produce, post and interact using text, images, video, and audio to communicate, share, collaborate or network. This includes, but not limited to blogs, podcasts, discussion forums, on-line collaborative information and publishing systems that are accessible to internal and external audiences i.e. blogs, social networks, wiki’s, videos and photo file sharing, information sharing, tagging, podcasting and vlogging, and other similar tools (Twitter, Facebook, LinkedIn, Reddit etc.).

3.0 Policy: This section includes principles, standards and responsibilities of employees when posting on their own accounts, commenting on other sites and using social media on SJHH network computers.

1. Actions inside and outside of the workplace can affect your relationship with SJHH and SJHF if such behaviours may impugn the reputation of SJHH staff, physicians, researchers, learners, donors and/or patients.
2. Disclosing information on social media may affect the employment of appointment and privilege relationship.
3. Any SJHH staff who violates this policy may be disciplined under the Hospital’s disciplinary process up to and including dismissal.

3.1. Guidelines for Personal and Professional Social Network Activity

3.1.1 Follow all applicable St. Joseph’s Healthcare Hamilton Policies at all times.

3.1.2 Confidentiality of patient health information, personal and hospital information must be maintained. Consequences of breaches in confidentiality may be far reaching and in most cases not anticipated at the time of occurrence. Any of these situations could jeopardize optimal patient care, effective job performance and place the hospital and staff member in contravention of legislation and at legal risk.

3.1.3 . St. Joseph’s Healthcare Hamilton supports the use of social media for informational purposes. St. Joseph’s healthcare staff, physicians, researchers, contractors and learners are permitted to have access to social media sites, provided that while at work, for educational and/or business purposes; this participation does not interfere with professional commitments.

3.1.4. SJHH employees using personal accounts, and so choose to represent themselves as employees of St. Joseph’s Healthcare Hamilton, consider how they are representing themselves and the organization, and how SJHH will thus be perceived.

3.1.4.1. Where your connection to SJHH is apparent or presumed, make it clear that you are speaking for yourself and not on behalf of SJHH, SJHS or SJHF. In those circumstances, you should include this disclaimer: “The views expressed on this [blog; website] are my own and do not reflect the views of my employer.”

3.2 SJHH Social Media and Web 2.0 Communications

3.2.1. Unless approved by the SJHH Public Affairs, your social media name, handle and URL will not include the St. Joseph’s Healthcare Hamilton, St. Joseph’s Healthcare Foundation or St. Joseph’s Health System name or logo, or an organization-related site/account.

3.2.2. Institutional representation via online social media platforms can only be initiated and authorized by the St. Joseph’s Healthcare Hamilton Public Affairs department under authority of the President, SJHH. Any sites or pages existing without prior authorization as required above will be subject to review when discovered and may be amended or removed.

3.2.3. Employees are encouraged to friend, follow, share and converse with official SJHH social media.

3.3. Confidentiality

3.3.1 Employees should be cognizant of standards of patient privacy and confidentiality that must be maintained in all environments, including online, and must at all times refrain from posting identifiable patient information of any kind online.

Reference to Admin Policy 65-ADM
Reference to 090-ADM
Employees of SJHH adhere to laws regarding the protection of confidentiality. Such as PHIPA (2004)

4.0 Procedure: In order to protect SJHH, staff, clients and partners, the following procedures are in effect regarding participation by employees on social media networks, while on SJHH network computers and personal devices.

4.1 Before publishing any material online, remember that what you post online is legally considered public material and as such each employee of SJHH is personally responsible for his or her publications.

4.1.1 Do not publish materials that are insulting, demeaning, or offensive to SJHH, SJHF, SJHH staff, physicians, researchers, learners, patients, clients and families, or any community partners, or that damages our reputation in any way.

4.1.2 Do not reveal confidential information related to SJHH, our staff, our clients and families, SJHF, or any community partners. Do not disclose the names or personal information of your co-workers, managers or supervisors, or discuss incidents that have occurred in the workplace and that are not generally known outside of the workplace. Remember our legal responsibility for our patients’ privacy and confidentiality.

4.1.3 Unauthorized use of SJHH brand or patient information or other information that results in legal action of any kind will not be covered by SJHH insurance or legal coverage

5.0 Documentation:
None

6.0 References

6.1 Internal References
Communication System policy -069-ADM
Reference Confidentiality 065-ADM
Privacy of Personal Information -090-ADM
Breach Patients Privacy -092-ADM
Wireless Communication Policy -106-ADM
Internet Security Policy- 107-ADM
Email Security policy-108-ADM
Use of Wireless Transmitting Devices- 119-ADM
Public Affairs and Media Relations- 027-ADM

6.2 External References

Personal Health Iinformation Protection Act, 2004. http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_04p03_e.htm

7.0 Sponsor
Manager, Public Affairs

8.0 In Consultation With
Chief Information Officer Chief, Privacy Officer