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Social Media Policy

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Reflecting MultiCare Values and Policies in Social Media

Scope

This Social Media policy applies to all employees, contractors, vendors, business partners, or other parties with a material interest in MultiCare Health System (MHS) and its affiliated entities, absent other specific authorization by MHS.

Policy Statement

Every employee or contractor at MultiCare Health System has actual or potential access to Social Media, and we recognize that permitting our employees and vendors to use these technologies responsibly may be beneficial to both MHS and the individuals involved. We want to promote an engaged workplace, in which employees feel able to express themselves freely and openly.

This policy lays out guidelines that MHS employees and contractors should keep in mind when using Social Media sites in reference to MHS. The main thing to remember is this: All applicable MHS policies also apply to any Social Media or other online activities. You are still responsible for protecting our patients, our professional reputation and yourself. Remember that everyone at MHS has a responsibility to ensure the seamless operation of MHS hospitals and clinics by following established policies and completing the work he or she is paid to accomplish. Personal use of Social Media and related social networks, like the personal use of cell phones, the Internet, and email, should be reserved for non-work time, unless there is an emergency.

MHS does not routinely target an individuals' use of Social Media, but we do monitor online use of our trade names, proprietary or confidential information, branding identity, and copyrighted information. MHS is not precluded from investigating an individual's Social Media usage or publicly accessible Social Media accounts when circumstances call for it. The use of any MHS computers, telephones or other digital devices, including MHS network resources, for the transmission or receipt of Social Media, creates no expectation of privacy by any individual on either end of such communications and MHS reserves the right to audit and monitor all use of all MHS equipment and networks at all times.

Be aware that disciplinary action can occur for violations of this policy and can include termination of employment or contract, and other interventions deemed appropriate by Human Resources, Corporate Compliance and/or Legal Services.

Special Instructions

We recognize that Social Media technologies continue to expand and change. To this end, this policy shall be read as an evolving policy, encompassing all mediums of human interface and interaction including, but not limited to: instant messaging, text messaging, personal websites, blogs, professional networking websites, and rapid-fire communications.

Procedure

I. What you should consider doing…

A. Be authentic. Whenever you post or comment in Social Media, state your name and write in first person. When making comments about MHS, or MHS-related matters, you must disclose your connection with MHS, and your role at MHS.

B. Be transparent. Unless you are authorized to speak on behalf of MHS, you should state that the views and opinions expressed are your own. A disclaimer is recommended: “The opinions contained on this site are my own and don't necessarily reflect [my employer's] or [MHS's] positions, strategies, or opinions.”

C. Be accurate. Errors and omissions could reflect poorly on MHS and on yourself. If you make a mistake, acknowledge and correct it.

D. Be professional. Be respectful to fellow employees, business invitees and partners, competitors, and patients. Avoid using unprofessional online personas.

E. Be smart. Use good judgment and ask the following question before posting comments relating to MHS: Could you be guilty of leaking information, trade secrets, patient/customer data, or upcoming announcements? If the comment would enable a reader to piece together confidential information, don't post it.

II. What you should never do…

A. Don't betray our patients' trust. Remember that disclosing confidential patient Protected Health Information (PHI) in an inappropriate manner is a federal offense. The penalties include significant fines. MHS employees should never publicly make comments about the care of a specific patient online, unless MHS policy allows such comments within the scope of the employee's employment at MHS. Even acknowledging the provision of care to a patient may be a violation of HIPAA. Likewise, even seemingly oblique references to individuals may constitute a HIPAA violation if the reader can piece a comment together with other identifying information, such as “We cared for that poor [grandmother/son/daughter] whose family died in the [fire/train wreck/boating accident] last week….”

B. Don't make endorsements. Endorsements of products, services or your employer without disclosure of your relationship to that product, service, or employer compromises your integrity and can place your employer at risk. Undisclosed relationships in endorsements can be a violation of federal regulations.

C. Don't cheat your employer. While at work, your primary responsibility is to MHS – refrain from using Social Media technologies when you are supposed to be doing your job and consider the impact of Social Media on MHS' network traffic as well as the diversion of your attention from your primary job or contractual responsibilities.

D. Don't get fired. Be wary of making statements that could be harmful to MHS. While occasional constructive criticism fine, it is not okay to post any of the following:

1. Work-related information that may compromise MHS's business practices, patient privacy and security, or organizational security;

2. Derogatory or inflammatory remarks about an individual or an individual's race, age, disability, religion, ethnicity, national origin, physical attributes, sex, sexual orientation, marital status, veteran's / military status, or health condition;

3. Copyrighted or trademarked information; or

4. Confidential or proprietary information of any kind or nature.
NLRA Exception: Note, notwithstanding the specific provisions of this Policy, comment within the scope of activities protected under the National Labor Relations Act (NLRA) may be protected and, as such, no action will be taken against individuals engaged in authorized and protected communications conducted pursuant to the NLRA, if the context of such protected communications is self-evident, and if conducted in a means, manner and location otherwise authorized by laws and rulings applicable to the NLRA.

5. Don't alienate your co-workers. Use common sense, and don't gossip or post disrespectful comments about your colleagues. Remember, you work with these people.

6. Don't assume that your comments will stay private. Even though social media technologies have privacy controls, you should assume that anything you post may be seen by the general public, as well as by your employer. Remember that your friends can copy your posts and make them available to the public.

III. What you should never disclose…

A. Patient Information. Under no circumstances may patient information be released for reasons other than authorized by MHS policy. The capturing of patient information, including digital images (Still or Motion) or audio, via any device, including unintentional capturing, must conform to MHS policy or may otherwise constitute a violation of HIPAA and/or Washington State laws. Employees and contractors are responsible for any capturing, dissemination, or use of PHI by themselves or anyone acting in concert with such employee or contractor.

B. Co-Workers / MHS Business Invitees. Do not capture images and/or audio of co-workers or other MHS Business Invitees (physicians, visitors, EMT personnel, technicians, etc.) unless authorized by MHS policy.

C. Intellectual property, trade secrets, or customer data. Do not disclose MHS's intellectual property, trade secrets, or patient/customer/employee/contractor data unless authorized by MHS policy. This includes the use of any MHS trademark, tradename or service mark in any Social Media context, as well as information pertaining to MHS physical plant security measures, network security, personnel identification, or other detailed operational data concerning any MHS operations, facilities, or personnel at any location.

D. Online Recommendations of Current or Former Workers. MultiCare Health System policy does not allow its employees to participate in Social Media or other online recommendations of individuals for employment-recommendation purposes. All communication of this type should be referred to Human Resources.

E. Financial information. Do not disclose MHS's financial or operating data or information of any kind or nature on Social Media unless authorized by MHS policy.

F. Anything that would violate any MHS policy or procedure: Again, we must emphasize that Social Media creates new tools for expression, but does not create a new world of communication and responsibilities. You are always obligated to follow MHS policies and procedures.

IV. Questions and Concerns:

A. Questions:
The MHS Departments of Marketing & Communications, Human Resources, Legal Services, Corporate Compliance, and Information Services are each available and ready to answer your questions about how Social Media affects you, both in the workplace and elsewhere. You can direct your questions to socialmedia@multicare.org or compliance@multicare.org or compliance@goodsamhealth.org

B. Concerns:
If you become aware of any use of Social Media in any context which appears to deviate from this policy, please contact socialmedia@multicare.org as well as your supervisor at your earliest opportunity. Anonymous communications can be directed to the Corporate Compliance Hotline (253-459-8300, 253-697-2100 or 866-264-6121) or to MHS Legal Services at 253-403-1107. Also complete a MeQIM as called for under the circumstances. See Midas Electronic Quality Improvement Memo on the MHS Home Page: http://mhsnet You can also direct your concerns to socialmedia@multicare.org or compliance@multicare.org or compliance@goodsamhealth.org