Adopting a social media policy in light of the Charity Commission’s new social media guidance

What will new Charity Commission guidance mean for your organisation’s approach to social media?

In September, and following substantial engagement from the sector, the Charity Commission published their long-awaited social media guidance. As recognised by the Commission, social media can be a great tool for charities to engage with their beneficiaries and raise funds and awareness of their activities. However, recent news stories highlight how the use of social media may inadvertently harm charities’ reputation; charities should be alive to the risks of failing to monitor the dissemination of harmful content, and the sharing of personal and potentially inflammatory views through the charity’s official channels. 

Below we explore some of the key takeaways of the Commission’s guidance, and how this may inform your charity’s future interaction with social media through the adoption of social media policies. 

Adopt a social media policy

Recent Charity Commission inquiry reports highlight how good charity governance relies on creating and consistently following policies and procedures. Any charity using social media should have a social media policy, though its content should be tailored to the needs of the charity, and should take into account the activities of, and resources available to, the charity. 

The Commission has produced a helpful checklist for charities to review existing (or create new) social media policies. In particular, it suggests charities consider: 

• How your charity will use social media – objectives, platforms, and content moderation;

• Oversight and control – who can post? When is additional approval needed (e.g. high-profile announcements)? Who is responsible for moderation? How and when can content be deleted?

• Required conduct for those managing the account – monitoring compliance with the policy, ensuring staff/volunteers have the skills and knowledge to use social media appropriately;

• Relationship to other policies – including its relationship to the charity’s guidelines on personal social media use by trustees, employees or volunteers (see below);

• Responding to incidents – When will issues need to be reported to the trustee board? How will the charity respond to complaints? Does a serious incident report need to be made? 

An effective policy is as much about risk management as is it about ensuring there is effective oversight, training, and communication channels amongst those engaging with it. Trustees should consider not only the charity’s online presence, but also how this is to be recognised and adopted at all levels of the organisation. Trustee, staff, and volunteer social media training should be an initial consideration, but trustees must also set aside time to review the continued suitability of their policy where necessary. 

Paul Latham, Director of Communications and Policy at the Charity Commission, in a recent press release, highlighted social media as a “high profile and fast paced area” of charities’ operations, and it follows that charities must continue to review their policies to ensure they are adapted as social media usage continues to evolve. 

Navigating acceptable content: risk, harm, and emotive topics

The Commission’s guidance defines the boundaries of acceptable social media content. A charity’s social media policy and training should make clear that the charity should not post or share content which is: 

• harmful – in simple terms, anything which may cause a person distress or harm (though the Commission recognises that what may be harmful to one person may not be to someone else);
• inconsistent with its charity’s purpose(s);
• not in the charity’s best interests;
• in breach of the law – such as UK GDPR, privacy, copyright, defamation, whistleblowing, equality, and human rights legislation.

The Commission’s guidance recognises, however, that, “charities can be involved in issues that provoke strong emotions” and may engage with these topics on social media if this achieves their charitable purpose(s) and is in the charity’s best interests. Critics have highlighted a potentially unclear distinction between “emotive topics” and “harmful” content. Ultimately, an assessment of which side your content falls on will likely depend on your charity’s usual operations and broader contextual factors. It is therefore imperative to plan appropriately, as the Commission highlights, by considering: 

• the risks to the charity and mitigation actions – including informing stakeholders;
• the impact on charity resources and staff – including managing complaints and abuse. 

Again, these considerations will likely form a central part of all charities’ social media policies, but particularly for those engaging with emotive topics. 

Further rules apply to political campaigning and fundraising on social media, and charities must also be mindful of the terms of use of each social media platform.  Legal advice may be required in certain circumstances. 

Personal social media usage 

In response to concerns relating to the “identification and management” of the risks of persons connected with the charity sharing harmful content on their personal social media pages, the Commission’s new guidance explicitly states that there is no expectation on trustees to monitor personal social media accounts. Charities should, however, produce and share guidance as to appropriate usage which may reference: 

• the potential for an individual’s personal use of social media to impact the charity;

• that trustees or others in specialist or senior positions should take particular care as personal views may be mistaken as the charity’s views;

• that individuals should make clear the views they share on their social media accounts are their own and not those of the charity;

• the consequences of breach of such guidance. 

Finally, special care needs to be taken as we head into an election period.  If you are in any way unsure of how to tailor your policy with this in mind, it may be necessary to take specialist legal advice.