By now you may have seen the draft Charity Commission social media guidance, which was published earlier this week. The aim of the guidance is to help trustees develop ‘appropriate shared understanding of the charity’s use of social media and the particular risks it can bring,’ and to encourage charities to, ‘adopt a policy on social media as a way to set their charity’s approach.’
The guidance is out for consultation until 14 March and you can respond here. Charity lawyer Rosamund McCarthy Etherington has already commented on it.
I’ve read through the guidance and I’m going to share my thoughts on it below. There are some useful things in the guidance, along with points I’d love to see clarified. I also have questions about how charities can implement it.
I’m also going to discuss how I’ve seen charities manage risk on social media, based on years of working with charities of all sizes on digital crisis comms in some very challenging situations. This includes advising on major reputational damage, from trolling to serious incidents, and drafting social media policies. I hope this advice helps you plan for how to implement this guidance as it stands (it is likely to change post consultation) and manage risk on social media.
Remit of charities’ use of social media
One of the key messages in the guidance is that charities should, ‘ensure you use social media only to help you achieve your charity’s purpose (what your charity was set up to do) and in a way that is in your charity’s best interests.’
I would like to understand what the Commission has in mind here as it is very different to how charities are using social media day to day. Does it mean that charities can only talk about their objects? How narrowly do charities need to apply this? It doesn’t reflect what charity supporters and donors are looking for from these platforms.
Earlier this week I spoke to a digital leader in a large charity who was concerned that operationally, the guidance does not reflect how social media works in practice.
What will happen to charities who use social media for partnership building, service delivery or being part of sector campaigns? How can charities offer meaningful supporter care on social media if posts need to be about their objects?
In practice, it would be very hard for charities to follow this.Charity supporters’ needs from social channels are rich and varied.
Social media policy
The Commission is encouraging charities to develop social media policies as part of this guidance. However I think there are a few things missing here, which are needed in order to implement these policies. And they have to be done in a way that is proportionate to the size of the charity.
A policy would normally include what the accountabilities are and what will happen if staff or volunteers breach the policy. It would be helpful to see this included as best practice here.
The guidance says that charities should ensure ‘trustees, staff and volunteers using social media are familiar with the charity’s social media policy.’ I’ve worked with charities who offer training and coaching to staff to make sure they are familiar with the social media policy.
However you do it, a social media policy has to be approached differently to a normal policy. It needs to be a living document. It’s different to, say, an expenses policy which you might only look at when booking a train ticket for work.
The social media policy needs to dovetail with your charity’s other policies and whilst some are referenced in the guidance it would be good to see the IT policy mentioned.
Process
It is helpful that having a social media policy and creating clarity about who should be involved when things go wrong are mentioned in the guidance. However, any organisation will need more than this to get them through a comms crisis.
Having gone into charities in the wake of high profile crisis situations the biggest pitfall I’ve seen is where there isn’t a clear digital crisis comms process in place. All the key people in the charity, from trustees to the digital and comms teams (or volunteers who are doing those roles) need to know what to do and when.
As part of this, you need a shared understanding of which kinds of content needs to be escalated and when, and who is responsible for this.
I’d like to see all of the above spelled out in the guidance.
If your charity has the resources to do it, I’d also recommend testing out your process ie running a digital crisis comms simulation before a major incident occurs. That way everyone will have the muscle memory of what to do when the worst happens.
What do charities need to know?
The guidance states that charities need to ensure their social media is ‘likely to be compliant’ with a wide range of law from GDPR to copyright to defamation to equality and human rights laws.
Whilst this is fine in principle, and of course no-one wants their charity to fall foul of the law, it will place a huge compliance burden on those managing social media.In particular, where will small charities find the time and money to get up to speed with the intricacies of these laws?
Even the digital teams I’ve worked with in large charities are overstretched because of the demands from other teams and the amount of proactive and reactive content they need to manage.Expecting them to have a working knowledge of these laws will be challenging.
Managing risk
How are charities expected to manage risk on social media? The guidance says that trustees are ‘responsible for identifying and managing risks’ such as staff or volunteers using their personal accounts, whether linked with the charity or not, to share content which does not reflect the views of the charity.
When I am running social media training or writing a social media policy I say to people that you should never post anything that you wouldn’t be happy for someone else to screenshot and share. Another test is: would you say this on stage at a conference? On that note, the guidance sounds sensible.
However, the guidance is very widely drafted here. Does it mean that trustees have to be across all of the potential risks in this area? However good your social media policy and training is, this could mean investing more time in proactively monitoring content shared by staff and volunteers. Again that could create a huge burden for smaller organisations, and larger ones. And what about ‘dark’ social media eg instant messaging, WhatsApp and messages in closed Facebook groups? No-one can be across everything.
The other issue I have questions about in the guidance is where it says: ‘Your charity can engage on emotive or controversial topics if this is a way of achieving its charitable purpose and is in the charity’s best interests.’ Surely engaging in these topics is the bread and butter of what many charities do on social media?
Again some of the steps the Commission advises here such as planning for the impact on resources, informing key stakeholders and complying with rules and regulations sound reasonable. And yet, when charities are already so stretched, how might this be achieved proportionally? If your charity works in an especially sensitive area, should you be planning for the fallout from every single tweet?
What next?
If your charity is concerned about, or has any comments on the guidance I encourage you to respond to the consultation before 14th March. You can do so here.
Whilst there will be charities and trustees who find this guidance helpful, there may be others who are now worried about what they can and can’t say on social media. Others could be wondering whether they need to change their approach and how this could impact supporter engagement, fundraising, service delivery and campaigning work.
This brings us back to what social media is really for, and its role in the sector. Social media gives charities the ability to champion the needs of the people they support. The platforms enable all of us, regardless of size or cause, to speak truth to power.
These roles are a vital part of charities’ work. This is what we are all here to do. And we must keep doing it, because it is needed now more than ever.