Draft Online Communications Policy Date | Time | Place
Table of Contents Purpose ...........................................................................................................................................................3 The Team .............................................................................................................................................................3 Our Online Communications Team includes: ........................................................................................3 The Tools .............................................................................................................................................................4 Facebook ........................................................................................................................................................4 Website ...........................................................................................................................................................4 Communications Contact List (Highrise) ...............................................................................................4 Purpose of Online Communications ............................................................................................................5 User Access ........................................................................................................................................................5 Facebook ........................................................................................................................................................5 Website ...........................................................................................................................................................6 Members Privacy ...............................................................................................................................................6 Contact and Personal Information of Members in the online database ..........................................6 Photos and Videos posted to Social Media and Website .....................................................................8 Intellectual Property and Copyright Laws ...................................................................................................8 Online Communications Procedures ...........................................................................................................8 Zero Tolerance Policy ..................................................................................................................................9 Sample Policy Violation Warning Script .............................................................................................10 Code of Conduct for the Communications Team ...............................................................................10 Community Member Engagement ..........................................................................................................10 Additional Guidelines ................................................................................................................................12 Workflow .........................................................................................................................................................13 Definitions ........................................................................................................................................................13 Facebook ......................................................................................................................................................13 Manager ....................................................................................................................................................14 Content Creator ...................................................................................................................................14 Website .........................................................................................................................................................14 Administrator .........................................................................................................................................14 Editors ......................................................................................................................................................14 Contributors ...........................................................................................................................................14 Subscribers ..............................................................................................................................................14 Highrise ........................................................................................................................................................15 Account Owner .....................................................................................................................................15 Administrators ........................................................................................................................................15
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Purpose To support Lynx River Band Council, administration and staff to effectively communicate online with Lynx River members. Effective communications with members’ means: • A robust and continuously updated contact database is available to the communication team • Modern tools are implemented in line with the communications needs and preferences of members, no matter where they live • It is widely known by members where they can go for more information about Band services and initiatives • Opportunities are created for members to provide feedback on band initiatives and issues effecting the community • Members questions are answered in a timely and respectful way • As much as possible, members concerns and feedback is reflected in the decision made by staff and Council The result of effective communications is: • Members are informed about band program, issues and initiatives • Decisions of Council and staff reflect the needs and priorities of members • Members are more trustful of Band staff, administration and Council
The Team Lynx River Band Council, administration and staff each play a unique communications role with members. Band staff communicates with members about matters related to their specific programs and initiatives, for example: health, education, recreation and other. Councillors communicate with members on a wide range of topics including issues facing the community, decisions of Council and other broad reaching topics of importance to the community as a whole. While certain Band staff will be the primary administrators and moderators of the online tools, it is important that everyone be aware of the policy and guidelines governing their use.
Our Online Communications Team includes: The administration, maintenance and coordination of the Lynx River online communications tools will be the responsibility of the Lynx River Communciations Officer.
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Online communications support will also be provided by: • Designated staff from each Department • Indian Registry Administrator In deciding who from each Department will support the Communications Officer to maintain the tools, it is important to note the it is best practice to assign this role according to “best fit” in terms of technical skill and level of knowledge about the program, initiative or service. Each team member is responsible for monitoring the Facebook page, and using the Social Media Guidelines below for responding to comments related to his or her department. By distributing the responsibility across the team, we will ensure issues are flagged, and comments and questions are dealt with quickly and effectively.
The Tools Please note the administrator terms vary between tools. For full descriptions for each of these administrator terms, please refer to the Definitions section at the end of this document.
Facebook The entire online communications team will be responsible for populating, maintaining and monitoring the Facebook group. However, specific roles include: • Manager – Communications Officer • Content Creators - Designated representatives from each department and reception.
Website The entire online communications team will be responsible for populating, maintaining and monitoring the treaty information website. However, specific roles include: • Administrator – Communications Officer • Moderators - Designated representatives from each department and reception.
Communications Contact List (Highrise) There are two levels of permission within Highrise, ensuring only the account owner can delete or add administrators and view account data. The entire online communications team will have the ability to add or update contacts to the contact database. • Account Owner – Communications Officer
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• Administrators – Indian Registry Administrator and designated representatives from each department and reception With the exception of the Communications Officer, Indian Registry Administrator and Director of Finance, designated department representatives will only have access to contact information for members they would normally communicate with as part of delivering their respective program or service of as permission is granted by the Account Owner.
Purpose of Online Communications All content shared using an online tool (email, web, social media) will support the goal of keeping members informed and seeking members feedback about band related issues and matters affecting the community. The following is a list of examples of band related content: • Band services and program updates • Events and gatherings sponsored or endorsed by the Band • News/Press items concerning the Band • Messages and updates from Mayor and Council • Economic opportunities for the community as a whole / individuals (e.g. job postings, information about band owned businesses) • Notices of events affecting the community • Photos / videos of community events The following is a list of examples of content that is not band related: • Personal opinions about leadership, other staff, band initiatives or issues affecting the community • Life events such as births, graduations, and marriages • Event and gatherings that are not sponsored or endorsed by the Band • Gossip, rumours or hearsay • Promotion of independent (member-owned) businesses or projects • Political campaigning
User Access Facebook As a public site, anyone can ’Like’ our page, see our content, and contribute to dialogue. Members will only have their comments deleted and/or be blocked from the Facebook Page pursuant to the ‘Zero Tolerance’ policy (described below).
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Website As a public website, anyone will be able to find the website through a search engine or a link from another page. Only band staff and administration will be able to create new posts on the website.
Members Privacy Contact and Personal Information of Members in the online database First Nations Band councils are obligated to protect personal information of their members in accordance with The Personal Information Protection and Electronic Documents Act. The Act requires that relevant organizations such as Band Councils that collect, use or disclose personal information do so in a manner that recognizes the right of privacy of individuals. It sets out 10 principles for compliance addressed below: 1. Accountability for information held in the communications contact list The [Communications Officer] is responsible for ensuring Lynx River Band is compliant with the Act. With respect to privacy, this role entails: • Maintenance of the privacy policy; • The development and delivery of staff training programs and materials concerning the policy • Sharing information with Lax Kw’laams members regarding the privacy of their personal information within the communications database 2. Purpose of collecting and maintaining personal information of members in the communications contact list • Information contained in the database should be used for the sole purpose of communicating with members about Band business, events, programs, issues and initiatives. 3. Informed consent • All communications with members from the contact database with provide members contacted with the option to avoid receiving further communications from the Band. All communications should be clear that by choosing this option, they will no longer receive important communications regarding band issues and initiatives, except in case of emergency. • All communications with members from the contact database, 4. Respectful collection of personal information • The type of information collected and maintained within the database for the purposes of communication include:
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• Names (First, Last, Middle, Alias) • Contact information (Phone, Address, Email) • Year of Birth • Residency (on/off reserve) • Participation in Band Communication Initiatives (Surveys, Open Houses, etc.) • Tribal Affiliation Additional types of information should be collected only for the purposes of communicating with members. If in the collection of personal information a member requests not to be contacted, a “do not contact” tag must be added to their contact and they will only be contacted in case of emergency. 4. Respectful use of information • If in the use of personal information a member requests not to be contacted, a “do not contact” tag must be added to their contact and they will only be contacted in case of emergency. 5. Disclosure of information • Information contained in the online database must not be disclosed to any third party without permission of the individual member. 6. Accuracy of information • Members contact information will be kept up to-date through the consistent use of workflow procedures set out below. 7. Safeguarding information • The Communications Officer will ensure that the appropriate level of permission is assigned to Band staff who use the contact list to communicate with members • Employees will not share their passwords. 8. Openness: • The privacy provisions within this policy should and updated on the Lynx River website 9. Requests for personal information • Members have a right to access the personal information that the Band holds about them in the contact list. Upon request, a digital (as csv. or exl file) or paper copy will be shared upon request.
10. Process for handling privacy complaints
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Any member may address a challenge concerning the Band’s compliance with the Act. If a complaint is received by anyone on the team, the following process will be followed: • Details about the complaint, and contact information for the complainant will be immediately forwarded to the Communications Officer • The Communications Officer will contact the complainant to request that the complaint be given in writing if not already received • The Communications Officer reviews the complaint and responds with 24-48 hour. • If the complainant is not satisfied with the response, the Communications Officer will provide him/her with contact information for the Privacy Commissioner of Canada who may investigate the complaint.
Photos and Videos posted to Social Media and Website It is equally important to respect the privacy of members when posting photos and videos of members on the website and Facebook. Two key guidelines should be observed with respect to this type of content: • Photos/videos of just the member or individual youth: When the team has photos they would like to publish online, the contact database must be checked to determine who to contact. If a member, or guardian of a youth portrayed along in a photo/video has requested not to be contacted, that photo/video cannot be published. • In the event that the member has consented to being contacted for band related communications, they should be contacted directly by email or phone to request consent to publish their photo/video. Whether consent is provided or not, details about the request should be recorded in their contact record in Highrise. If multiple members are depicted in a photo/video at a public event, it is acceptable to post to the website and Facebook without consent. In the event that a member expresses concern about the published material, it should be immediately removed and a Treaty Communications Coordinators should be alerted and respond to the member as soon as possible.
Intellectual Property and Copyright Laws It is critical to be aware of and abide by the laws governing copyright and fair use or fair dealing of copyrighted material owned by others, including Lynx River own copyrights and brands. You should never quote more than a short excerpts of someone else's work, and always attribute such work to the original author/source. It is good general practice to link to others' work rather than reproduce it.
Online Communications Procedures Page 8
While it is not possible to control the topics and issues members choose to discuss online, it is important to establish guidelines for the team to use when posting content and answering questions posed by members. The following procedures relate to content posted by Lynx River staff online, and should serve as guidelines for the ongoing management of the Lynx River Facebook Profile and Page as well as other online tools as they are implemented over time. While we cannot control the topics and issues members discuss online, it is important to establish guidelines for the team to use when posting content and answering questions from members as they arise.
Zero Tolerance Policy The communications team will not tolerate offensive (including foul language) or abusive comments made on the Facebook page or profile or other online tools. Known as the ‘Zero Tolerance’ policy, this means that when a user (e.g. Facebook friend) posts an offensive or abusive comment it must be removed immediately. It is important that users are aware of this policy. It should be clearly stated on the Facebook Page wall, and pinned to the top so it always remains the topmost post. Please note, the policy will need to be restated as a status multiple times on the Facebook Profile to ensure community members will see it and read it. The following is an example of the policy statement: This Facebook page is intended as a safe place for members to discuss their views. We have a zero tolerance for foul language and offensive or abusive comments toward anyone. We welcome and encourage respectful dialogue. It is critically important to be vigilant in the enforcement of this policy and quickly address offenders. People need to know the Facebook page and profile will always be a safe place for constructive dialogue or they will quickly lose trust in the band and its communication procedures. Beyond the purpose of wanting to ensure members feel the band Facebook Page and Profile and other online forums are safe spaces for constructive dialogue, sharing and implementing this policy will help protect the band from any allegations of libel (i.e. a published false statement that is damaging to a person’s reputation / written defamation). The following steps will be taken if a comment is made that violates this policy. • The comment / post will be deleted as soon as it is seen. A reminder of the policy will be issued. • A communications team member will send a personal message to the user who made the offensive or abusive post, reminding them of the Zero Tolerance policy and informing them that any future violations of the policy will result in their being blocked from the forum. • If the individual has previously violated the policy, they will be blocked from the page. (numbers)
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Sample Policy Violation Warning Script Your recent [post / comment] on the Lynx River Facebook Page / Profile is in violation of our Zero Tolerance policy and has been removed. Please note that any subsequent posts that violate our policy (i.e. contain abusive or offensive language) will result in your being blocked from the page.
Code of Conduct for the Communications Team The communications team members will uphold the following foundational principles of communications when posting to Facebook: • I will not criticize Lynx River community members or give out their personal information • I will refrain from posting my personal opinions on the Facebook wall • I will acknowledge and correct any informational mistakes promptly • I will only delete comments / posts that I deem to be spam or offensive • I will disclose conflicts of interest where I am able • I will not discuss non-public information • I will not knowingly post inaccurate information • I will link to online references and original source materials directly • I will not delete a post unless it breaches this Code of Conduct
Community Member Engagement It is not necessary for the team to respond to every comment made about the community. Community members will engage in peer to peer conversations that may or may not be related to the band administration and decision making. The following flagging system outlines the types of posts that should be responded to, examples of appropriate response, and the maximum acceptable time within which a response should be posted by a team member. Blue
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Green
Yellow
Red
Type of Post
Neutral comment
Incidental organization mentions
Positive comment Dissatisfied about the comment organization
Question
Directed negative comment about Threats the band
Commentary about another nation or community Examples
Claims of harm Comment directed caused by our staff at a person or the band Our Elders have so Its great to see our The band always John Doe is a [#@ much wisdom to leaders working plans meetings at $%!] and the band share if we take the hard together to times people can’t should fire him time to listen provide a better attend future for all community John Doe is going members I attended a The band isn’t to get what’s conference keeping me coming to him overheard someone informed of what’s saying they didn’t going on realize our band was so big Jane Doe was rude to me when I phoned the office to ask a question
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Personal attack toward the band or staff
Response?
Action
None
None
Likely
Determine if the comment is relevant
Yes. Thank the person for their comment publicly and provide facts to correct any misinformation they have shared.
Yes. Warn commenter publicly and state the ‘Zero Tolerance’ policy on abusive or offensive posts.
Be clear that it is not necessarily what is being said - rather how it is being said. The goal is not to censor comments, but to ensure users are being respectful, even when they may be making challenging statements. Notify supervisors Notify project leads so they can decide and/or Committee the appropriate members so they person to follow can decide the up with the appropriate person commenter to follow up with privately the commenter privately
Block further comments as spam or remove them
Response Time None
Additional Guidelines
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Within 24 hours
Within 12 hours
Document first warning As soon as possible
• If a community member poses a question or comment that the communications team is unsure of the answer to, their comment will be acknowledged and they will be told that they will receive an answer as soon as possible. It is better to respond quickly and state a team member will follow up shortly than to leave a question unaddressed. • Team member should identify themselves at the end of a response to comments (as people like to know who is answering their comments). Comments can either be signed of with the team member’s full name or initials. • All violations of these guidelines and subsequent “blocks” from online forums will be recorded in the contact database, along with the name of the team member that initiated the block / responded to the violation.
Workflow To ensure that the tools are maintained and members are responded to consistently and in a timely way, the following procedures should be incorporated into the daily/weekly workflow processes of the communications team members. • Web posting requests will typically come from the Band Administrator, Assistant Administrator or Department heads. In the case of a community event or meeting, members should be given a reasonable amount of time to make arrangements to attend. • When new information is posted to the website, a brief introduction to the content and a link to the new webpage should be posted to Facebook. • To draw attention to a post, any posted to the web should include a photo along with the caption. Captions should be brief, and provide links to other webpages where more information on the post can be found. • Each team member should develop a daily process that works with his or her existing schedule for checking the Facebook at once a day. With as many as 5 people updating and moderating Facebook, each person is likely not to exceed 30 minutes of time spent on online communications. • Whenever someone engages with our team by responding to one our posts, asking a question via website, Facebook, phone, or email, it is that person’s responsibility to document the exchange in Highrise. This is especially important when someone from the team has needed to engage the ’Zero Tolerance’ policy.
Definitions Facebook
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Manager The Manager oversees the Facebook page or group. Managers are responsible for adding or removing other administrators, editing the page and adding apps, creating posts, responding to and deleting comments, sending messages as the Page, creating ads, and viewing statistics. Content Creator Content Creators are responsible for editing the page and adding apps, creating posts as the page, responding to and deleting comments, sending messages as the Page, creating ads, and viewing statistics. Content Creators cannot add or remove other administrators.
Website Administrator The Administrator oversees the website. They manage the look and feel of the website, including editing and importing or exporting data from the dashboard (often referred to as the ‘back end’). The administrator manages users, meaning they assign different levels of permissions to different users as guided by policy and best practice. The Administrator will not be responsible for communicating through the online communications tools. The singular role of the NSTC Technology Training Coordinator on this team is to administrate the tools by adding, editing, or removing team members as administrators for the tools, editing settings or controls, and technical support. Editors Editors can create, edit and publish content to the website. They can also moderate comments and reply to comments from site visitors. An editor can edit or delete others’ pages, posts, private pages and posts, and published posts or pages. They can also manage article categories, links, and other special functions of the site. Editors cannot delete or change users. Contributors Contributors have the ability to create content for the website, however, it can only be published once reviewed by an editor. Subscribers Subscribers are members who want to participate in the members-only section of the website, ask questions, comment on articles, and have conversations with other members. They cannot post articles, edit any content, and can be vetted and approved before being given access to the website.
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Highrise Account Owner The account owner is the only person that can access the Account page, upgrade, downgrade, change billing information, access invoices, and cancel the account. The account owner also manages all aspects of user permissions, including which contact lists can be accessed by administrators. Administrators Administrators can add contacts, tasks and custom fields as well as edit contacts within their range of permissions, but they cannot see account information or contact information for which they do not have the permissions.
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