In January the Charity Commission launched their draft social media guidance for charities. There were concerns about the guidance from many organisations and NCVO convened a sector response to the consultation. At the time we blogged about our views on the draft guidance as we were worried about how it would affect charities. The updated guidance was published earlier this week and you can read it here.
In this blog I’m going to share my thoughts on the guidance and make suggestions about implementation, including how you can make it part of your charity’s digital strategy. I’m going to look at all of these things in the context of the challenging climate we are seeing on social media, which I believe may get more difficult in 2024. More on that later.
Reaction to the guidance
The response to the updated guidance has generally been positive. NCVO welcomed the guidance, with CEO Sarah Vibert noting that it supports the role of charities in campaigning if it helps them meet their charitable objectives. Charity lawyer Rosamund Etherington has written about how the Commission has dealt with many of the concerns raised in the consultation. Charitycomms also responded positively and posted links to their social media resources for charities.
In our view, the final guidance is definitely an improvement on the draft. It is encouraging to see that the Commission has listened to the views expressed in the consultation.
What you need to know about the guidance
It’s good that the guidance fleshes out its original advice on charities’ social media policies. It has some genuinely helpful detail (such as a checklist of what your policy should contain, and links to useful resources such as those of the Media Trust) which charities who are new to social media, or who need support around managing risk will find useful. And parts of the new guidance are good old common sense- for example, that trustees, staff and volunteers should all be familiar with your charity’s social media guidelines.
I’m thoughtful about the burden of legal compliance as set out in the guidance. As I said at the time of our response to the guidance in January, it is right that your social media content should be compliant with GDPR, copyright law, defamation law and other relevant types of law specified in the guidance. However these are complex areas of law and charity digital teams will be more familiar with some areas than others. Your charity will need to consider how it can ensure that its social media content is compliant , which might involve training for those creating the content and also those signing off on it.
It’s helpful that the Commission has included managing the risk of being unduly associated with the comments made online by partner organisations. This is a sensible thing to do and you might want to plan how your charity would respond if, for example, a corporate partner was embroiled in a scandal. Of course this raises the question of how your charity should manage this risk, which I would interpret as being proactive about keeping an eye on what partner organisations are saying online and having a plan for what you would do if you noticed content which didn’t align with your charity’s values. This is not, however, spelt out in the guidance, which simply states that charities should ‘manage the risks.’
The tone of the updated guidance is also more balanced and proportionate than the draft, which is good to see. However, I do wonder if very cautious trustees, particularly if they are involved in running the channels at a small charity, might be a little nervous about the actions they now need to take to manage risk.
Someone asked me what charities should do if they are concerned about staff members expressing offensive views on social media. In our consultancy work we advise charities to deal with this in social media policies by stating that colleagues should be mindful that any views they express online should be consistent with their organisation’s values.
How to implement the guidance
What is really positive about this guidance is that it’s there to help trustees be aware of and manage the risks that come with social media. We need to remember though that this represents just one aspect of how to use social media, albeit an important one. To implement it successfully will require trustees, senior management, your digital teams and HR (or whoever represents these areas if your charity is small) to come together and work out the best way to adopt it in your context. And the good news is that there will be charities who are following a lot of the recommendations in the guidance already, because it includes good practice.
It would make sense to look at implementing the guidance at the same time as reviewing what your charity is doing well and what could be improved on social media. It’s really important that this guidance does not get put into practice in a silo. Yes, managing risk on social media is important, and that exercise can absolutely go hand in hand with seizing the opportunities for campaigning, reaching your community and fundraising that these channels offer.
It’s great that having a policy, and an accompanying plan and process has been expanded on in the guidance. Yet if there is one thing that differentiates the charities who thrive during a communications crisis, and those that don’t, it is being prepared. A good policy, plan and process will take you some way. What you need to do next is to drill it, so that when the crisis comes you and your team have the muscle memory to leap into action. It also means that any glitches will be ironed out through stress testing your crisis response.
As anyone who has been on social media recently knows, especially on X (as it is now known), the environment on these channels can be febrile. I was reminded of this when the news of allegations about Russell Brand broke last weekend. Social media rapidly became a very divided place, with Brand’s defenders criticising mainstream media and the timing of the allegations. Whilst this was happening, social media did not feel like a safe place to be.
This kind of culture war is just a taste of what we may see in 2024, with elections due to take place in the UK, US, India and Russia. It’s inevitable that we will see more polarisation, misinformation and disinformation online, with civil society caught in the backdraft. And it is likely to get worse because we may see bad actors using AI to create content such as deep fakes and fake voicenotes.
I worry about the sector amidst all of this. One of the things charities do is speak truth to power. It’s hard to do this when there are people online who have a murky relationship with the truth.
Yet the answer is not to leave social media. Nor should you be dialing it down. It’s essential that charities are on there to campaign, to fundraise and to reach the people we need to support and work alongside. You just need to be prepared for challenging situations, and the guidance is a good starting point for managing the risk that comes with this.
The final, and most important thing we must do is look after the people who are working on our channels. Social media can bring amazing opportunities for charities, and it can also be a very difficult environment. We need to make the wellbeing of those who manage our social media a priority. I hope trustees will realise this is as important as implementing the guidance.