Social Media & Communications Policy v1.002 2025-01-07

This policy is designed to steer employees use of social media and electronic communications, in a way that protects both the company and the individual.

Scope

These guidelines apply to ALL employees' use of social media & electronic communication, both in a professional capacity and in personal capacity that may impact the company.

General Principles

The following general principles of use should apply at all times...

• Exercise good judgment: Remember that your online activities may reflect on the company.
• Respect confidentiality: Do not share confidential company or client information.
• Be authentic: If discussing company-related matters, disclose your affiliation.
• Be neutral: Avoid any language or discussions related to gender identity or similar controversial topics even when referring to yourself.
• Be respectful: Avoid confrontational or offensive language, or any language that trigger anyone.
• Stay professional: Keep all communications work-focused and avoid engaging in discussions about sensitive social or political topics.

Relevant UK Legislation

Employees MUST be aware of the following UK legislation that may impact their social media and electronic messaging use. This legislation is convoluted, confusing and contradicting, yet any and all can be applied at any time.

• Online Safety Act 2023
• Public Order Act 1986 (as amended)
• Communications Act 2003
• Malicious Communications Act 1988
• Defamation Act 2013
• Data Protection Act 2018 and UK GDPR
• The Terrorism Act 2000

Professional Use

• Only authorised employees may speak on behalf of the company on social media or via electronic communications.
• When representing the company, adhere to our brand guidelines and values.
• Ensure all shared information is accurate and approved for public dissemination.
• Be aware that no online communication is secure, and its content is always at risk.

Personal Use

We cannot, and should not in a modern democracy, attempt to regulate your personal use of social media and electronic communications, yet we please ask that you...

• Clearly distinguish personal views from those of the company.
• Do not use your role, position, or the company in any social media posts.
• Be mindful that your personal posts may still be associated with your professional role.
• Avoid any content that is 'risky' below.

Legal Considerations and Real-World Consequences

It's crucial to understand that the UK government has enacted a series of laws to curtail freedom of speech and rights to protest over the last decade, and the police force are now actively leveraging these. There have been numerous cases where individuals faced legal consequences for their online actions. Whilst we would like to encourage open communication, this is no longer possible and employees should be aware of the following.

• Posting, reposting, or even liking certain types of content could potentially lead to legal action under various UK laws.
• There have been instances where individuals faced arrest, trial, and in some cases, imprisonment for social media posts deemed offensive or in violation of UK laws.
• Context and intent are unlikely to protect you from legal consequences. What one person considers a joke might be interpreted differently by the police.

Examples of potentially risky content include, but are not limited to.

• Following, Liking, commenting on, or sharing/reposting any content from anyone or any organisation that is thought to be anti-establishment, politically disruptive, or middle to far right.
• Posts that could be interpreted as inciting hatred or violence
• Content that might be seen as offensive or causing distress to anyone, even if no one that saw it found it so.
• Sharing of false information that some idiot may believe is true, even if, to you it's clearly not or satire.
• Messages that could be construed as threats, even though no normal person would consider as such, even if intended humorously.
• Any content that criticises central or local government, the police, any authority or public figure.

Balancing Personal Expression and Professional Responsibility

• When posting and sending non-work-related topics, consider using privacy settings to limit your audience.
• Be particularly cautious when discussing sensitive topics such as gender, sex, politics, religion, or current events.
• If you're unsure about a post or message, consider asking yourself: "Would I be comfortable defending this in court or to my employer?
• Remember that the company, unlike the government, respects your right to personal expression, but cannot and will not protect you from the legal consequences of your actions.

Privacy and Security

• Use strong passwords and enable two-factor authentication where possible.
• Be cautious about sharing personal information online.
• Be aware of phishing attempts and social engineering tactics.

Reporting Concerns

If you encounter concerning content related to the company or colleagues, report it to HR or your manager.

Updates

The UK Government is intent on curtailing freedom of speech at scale, and in order to keep relevant we will no doubt have to update this policy at regular intervals. You are REQUIRED to refer to this policy no less than monthly to ensure you are aware and compliant.

Consequences

Violations of this policy may result in disciplinary action, up to and including termination, and be considered GROSS MISCONDUCT within your contract of employment.