Sector Focus: Charity Commission launches guidance on social media

01 Nov 2023 Expert insight

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International charities are often dealing with emotive issues and will want to spread their message as widely as possible. Social media is an ideal tool for this – but it is not without its risks.

The Charity Commission has recently issued new guidance around charities’ use of social media, which recognises this.

Setting a policy

The guidance is clear that charities using social media must have a social media policy. As with other policies, the policy should be proportionate to the risks and needs of the charity. The guidance includes a checklist for developing a social media policy. This checklist is a useful tool, regardless of whether you have an existing policy, or are developing one for the first time.

Managing risks and challenges

Firstly, a key area for any social media policy to address is risk management.

Care should be taken over content that is posted or shared, and the policy should be clear that a charity should not post content which is harmful or inconsistent with its purposes.

Charities should also ensure their use of social media complies with relevant laws and regulations. This requires a sufficient understanding of those laws and regulations to ensure compliance. Again, this should be set out within the policy.

The consequences of higher-risk posts should be carefully considered and, as with any important decision, a proper record of the thought process should be maintained.

The Commission’s guidance is clear that charities can use social media to engage in campaigning and political activities. Particular care should be taken in this instance, especially around the time of elections, and it is important that all individuals involved are aware of the rules.

The nature of social media means that things can move quickly, so it is important that there is an appropriate plan in place to manage policy breaches or other issues. Again, where issues arise, proportionate action should be taken, and the key decisions recorded. Where the issues are significant, there should be a process for escalating the matter to trustees on a timely basis.

Blurred lines

Many individuals involved with charities will also use social media in a personal capacity. It is possible that things posted or shared in a personal capacity will become associated with the charity. This risk is heightened where it concerns the senior leadership of the charity, as it can be perceived that individuals acting privately are in fact acting on behalf of the charity. There are a number of ways this risk can be managed, for example by including a proviso at the beginning of a post or on their social media profile that makes it clear the individuals posting privately are doing so in a purely personal capacity and that their views are their own. To help manage this risk, the Commission suggests that social media guidelines should be shared with trustees, staff and volunteers.

Key questions to consider

Social media can be a very effective communication and engagement tool; however, it is important that the inherent risks are managed effectively. Trustees, staff and volunteers should familiarise themselves with the guidance and their charity’s policy and ensure that there are proportionate measures in place to address the risks. Some questions to consider are:

  1. Are you clear on how your charity uses social media?
  2. Does your charity have a formal social media policy?
  3. Assuming that it does, when was the last time it was reviewed?
  4. Who is responsible for maintaining and updating the social media policy?
  5. How is the policy (and changes to the policy) communicated to all relevant individuals?
  6. Are you clear as to the response in the event of an incident using social media?
  7. Are trustees, staff and volunteers clear on the guidelines for personal use of social media?
  8. Do you have appropriate processes in place to manage your social media accounts?
  9. If you engage on social media on challenging or emotive topics, do you have an appropriate plan in place and is your decision-making appropriately recorded?
  10. Do you have a clearly communicated complaints process and is that process fit for purpose?

Using social media inappropriately can have huge reputational risks. It is important that training is provided and reviewed on a regular basis.

Steve Harper is a partner at haysmacintyre 

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