Procedures

1.1 General Use. During working hours, FNU employees may not spend more than minimal work time on personal activities, including the use of social media. Use during breaks and meal period is permitted.

In some circumstances, a Vice President, or designee, may authorize use of personal social media sites and accounts that further University interests.

1.2 Acceptable Use. FNU equipment and resources, including in relation to social media activities, may only be used in accordance with the University’s Acceptable Use Policy Regarding Information Technology.

1.3 Activities Violating the Law or Policy. FNU employees may not use social media in ways that violate federal, state, local and, when applicable, foreign laws. For example, social media communications depicting child pornography violate criminal laws and FNU regulations. Social media communications constituting threats of violence, or known or intended to cause severe emotional distress, may violate the law and FNU regulations. Social media communications containing false statements that could harm a person’s reputation are possibly defamatory and may result in civil liability.

FNU employees may not use social media in ways that violate FNU regulations, policies, or procedures. For example, social media communications may not be used to violate FNU’s regulations prohibiting discrimination of a protected class or violate FNU’s policy prohibiting sexual harassment. In addition, in accordance with the University’s Abuse Prevention Policy, employees may not “friend” and/or accept friend requests from minors and vulnerable adults who are receiving services at FNU. It is acceptable to accept social network “friend requests” from students, alumnae, or parents of students/alumnae who are over the age of 18, but employees should maintain professional relationships with students, alumnae, and parents.

Uses of social media in ways that constitute criminal or civil actions or in ways that violate FNU regulations, policies, or procedures may be reviewed on a case-by-case basis. Substantiated violations of policy or law could result in disciplinary action, up to and including dismissal from the University.

1.4 Maintaining the Confidentiality of Student and Applicant Records. Federal laws, including the Family Educational Rights and Privacy Act (FERPA), Florida law, and FNU’s regulations governing the confidentiality of student and applicant records (and information from such records) apply to social media use. Personally identifiable information (PII) includes, but is not limited to, academic records, disciplinary records, correspondence through e-mail or other means, or, with limited exceptions, any other records individually identifying students at the University or applicants to the University. PII should never be released via social media without the prior approval of the Vice President of Operations. Before such approval is granted, written consent of all students and applicants whose PII will be released must be obtained unless the PII in question is directory information per the University’s FERPA policy and the student(s) has not opted out of allowing the University to share directory information without consent.

1.5 Safeguarding Patient Privacy and Patient Information. Use of social media, even in a personal capacity, must comply with state and federal law concerning patient privacy, including, but not limited to, compliance with the Health Insurance Portability and Accountability Act (HIPAA).

Covered entities subject to HIPAA may not improperly share or disclose, including via social media, protected health information (PHI), unless that patient (or patient’s parent/guardian) has provided advanced written authorization of the release of such information.

Patient information may not be posted on social media, even if it has been “de-identified.” Keep in mind the following:

1. It often is possible to identify patients even if their names or other obvious identifying information are not included.
2. Details, such as names, places of work/study, and the date/time stamp can make it easy to identify patients described, particularly to the patients themselves and their families and friends.
3. If patients contact those affiliated with FNU via social media, simply responding to a patient, without referencing medical advice or a medical condition, is acceptable. Providing medical advice or information through social media is not permitted, even if the patient requests it.

1.6 Improper Disclosure Research and Intellectual Property. Releasing unpublished research data or unprotected intellectual property may impair its protection. In keeping with the University’s Intellectual Property Policy, unpublished research data or unprotected intellectual property may not be released through social media in a manner that impairs patent protection, violates any condition of an applicable research contract or grant, or violates any applicable law.

1.7 Other Forms of Restricted Data. Revealing other forms of legally restricted records, data, or information via social media is strictly prohibited. Records protected include but are not limited to: Social Security numbers, financial information, employee or student medical information, limited access employee records pursuant to Section 1012.61, Florida Statutes, trade secrets, copyrighted materials, materials covered by export control laws and regulations, and other materials the University is required to maintain as confidential or has agreed to do so.

While those affiliated with FNU may disclose information about themselves, they should exercise caution in doing so for their own protection. Once disclosed through social media, the information may be accessed indefinitely and, in many contexts, (e.g., actual and potential employers, professional licensure authorities, elections, current and future family members) that may not have been contemplated at the time.

1.8 Misrepresentation. Those affiliated with FNU may not portray themselves as acting or speaking on behalf of the University or any part of the University, such as a department or division, or any other unit, or present a social media account as an official University account, unless authorized to do so by the President, or designee, with jurisdiction over the applicable unit.

Even when acting in one’s University capacity, FNU faculty, staff, students, volunteers, etc. may not represent their own positions and opinions on social media as those of the University. When using social media in a personal capacity, reasonable precautions must be taken to indicate that the activity is being conducted as a private person and not as an employee, agent, or spokesperson of the University. Precautions include using heightened privacy settings, not identifying oneself as a FNU employee, and adding a disclaimer clarifying the views expressed are that of the individual.

1.9 Professional Standards. Those employed or in a course of study in a field that is subject to professional or ethical standards (e.g., licensed physicians, nurses, mid-level providers, attorneys, accountants, etc.) must comply with those standards in their university capacity. Such standards also apply to one’s personal capacity if the standards generally apply at all times or if one’s personal conduct would affect or reflect on his or her university role.

Text, photos, videos, and other material posted on social media pages, including personal ones, should be in keeping with generally accepted professional and/or ethical standards for one’s field(s) of work and/or study.

Depictions of behavior that do not comply with professional and/or ethical standards may result in disciplinary action, up to and including dismissal from the University.

Remind other members of your network of your position at FNU and that your profile may be accessed by students and alumnae, and to monitor their posts to your network accordingly. Conversely, be judicious in your postings to all friends’ sites, and act immediately to remove any material that may be inappropriate from your site whether posted by you or someone else.

1.10 FNU Social Media Account Authorization. Authorization to present a social media account as an official University activity must come from the President as well as the Vice President of Operations or his/her designee.

Enforcement Failure to comply with this policy could result in disciplinary action, up to and including termination.