- Protocol for Authorising Access to Facebook / Other Social Media Sites
- Appendix 1: Social Network Search Request Form
- Appendix 2: Social Network Search Evaluation Form
This guidance is not intended to cover use by Social Care staff of social networking sites in their private and personal lives; rather it covers the use of such sites for the purpose of work, and specifically in relation to the gathering information about service users and their families, and known associates and/or suspected associates. (The HCPC Social Media Guidance contains useful tips for social workers and other professionals on how to use social media)
Where a member of staff maintains a social networking profile for their own personal use, this must NEVER be used to communicate with service users, or to convey official information.
What are social networking sites?
Social networking sites are constructed by individuals to share personal information with online ‘friends’. It is possible to specify, through the use of privacy settings who sees the information which is posted on an individual’s profile.
By posting information, including text and photographs, on a profile which is not protected by privacy settings, the person who makes the material available is, in effect, publishing it as an ‘open source’ to an unrestricted audience. It is reasonable therefore that this material could be viewed on a single occasion for specified purpose (e.g. to check associates or where there are reasonable grounds to assume information provided is misleading or untrue).
Where information is restricted to "friends" there is a clear intention to limit the use of the material and it cannot therefore be described as in the public domain.
Social work staff must not examine the social networking profile of service users using their own personal social networking profile. Wakefield Council have introduced a corporate private profile, with access limited to a small number of key staff, the use of which is subject to completion of an authorisation protocol.
Important issues to consider before requesting access to Facebook or other social media sites include:
- Confidentiality and consent of service users;
- The need to process personal data in accordance with data protection principles;
- The need for caution and corroboration - social media accounts can be infiltrated/faked. Service-users may have more than one online persona;
- Depending on the circumstances, the viewing of service-users’ social media accounts may constitute overt or covert surveillance requiring appropriate authorisation.
Information gleaned from searches of social media sites will constitute ‘personal data’ which must be processed in accordance with data processing principles. It must be:
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- Relevant and limited to what is necessary for those purposes;
- Kept for no longer than is necessary for those purposes;
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate personal data are erased or rectified without delay;
- Processed lawfully, fairly and in a transparent manner;
- Processed in a secure manner, which includes protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
It is good practice, where enquiries are likely to include searches of social media sites, to make service-users generally aware of this fact by including this in the information which is given to them at the commencement of the process, for example at the commencement of the Assessment.In specific cases, social media searches, as with other forms of information-gathering for Assessment purposes, should generally take place with the consent of the subject, unless there are valid reasons to the contrary. There may be an ‘overriding public interest’ in obtaining and sharing information without explicit consent.
2. Protocol for Authorising Access to Facebook / Other Social Media Sites
Originating Social Worker - Social worker who is undertaking an investigation or an assessment and has cause to believe that there may be relevant Facebook /other social media information.
Authorised Access Worker - Social Worker or Family Support Worker who is authorised to access Facebook / other social media sites using Wakefield Council log on.
Originating Social Worker is alerted to the need to check some aspects of a service user's and/or their family's/associate's account of current or recent events which might affect the safety of a child or children, i.e.
- Reasonable ground to believe that information given by a family as part of the assessment is misleading or untrue e.g. the claimed separation of a couple where domestic abuse is known to be a significant risk factor;
- Possible relationship between child and a known or suspected abusive adult;
- Presence of known risky behaviour, drug taking, drinking etc;
- Persons Posing a Risk to a child said to be present in family relationships.
In addition, older children may have their own social networking profiles and, in some circumstances, for example where there are concerns around child sexual exploitation or a child who is going missing, a search of their social media profiles might be considered helpful
Originating Social Worker discusses these concerns with their Team Manager in context of supervision and identifies potential ways in which concerns can be triangulated. The discussion between the Social Worker and the Team Manager should include consideration of the ethical implications of obtaining information from social networking sites, and agreement that such a search is in the best interests of the child. Decisions should be made on a case by case basis.
If Team Manager agrees that checking Facebook / other social media sites is an appropriate triangulation, the Team Manager will then request permission from the Service Director to make contact with Authorised Access Worker to request a check of Facebook.
The Originating Social Worker needs to be as specific as possible about the people and timescales to be interrogated. Normally the process will include a one off review of currently available information on a Facebook site. Regular / repeated checks of a service user’s social media sites / profiles are not recommended practice and may be taken to constitute covert surveillance.
The Originating Social Worker must complete the Search Request Form (Appendix 1: Social Network Search Request Form) and include the name and as many details as possible of each adult whose Facebook site it is proposed to check. This may include known associates and/or suspected associates. If there are suspected associate(s) whose name(s) is/are not known, these should be referred to in as much detail as possible (e.g. if there are concerns that the mother of children is engaged in an online relationship with an unknown man believed to be behaving inappropriately).
Authorised Access Worker has authority and responsibility to satisfy themselves that log-on is legitimate. If they have any doubts regarding the validity of this search they should refer back to the Service Manager and Service Director for further discussions on the subject.
Authorised Access Worker logs on and searches for requested information.
Throughout the process the Originating Social Worker and Authorised Access Worker should work together to identify what is relevant information is identified on Facebook. If there is any uncertainty or disagreement about the process, or the information which is being identified, there should be a discussion with Service Manager whose team is managing the case.
If it becomes apparent during the viewing of the site that it may be useful to look at Facebook pages belonging to another person, this needs to be processed as a separate request, and should be specifically brought to the attention of the Service Director.
A copy of any information which is identified as relevant must be taken and saved as an electronic document which should then be provided to the appropriate Service manager and Service Director.
Once obtained the copied information becomes part of the service user's formal social care record. It should be placed on Care Director in the "Assessments" box and must be retained and if requested made available as part of a data protection disclosure.
Authorised Access Worker completes an Evaluation Form (Appendix 2: Social Network Search Evaluation Form) and passes to Originating Social Worker.
Originating Social Worker assesses the information and finalises the Evaluation Form.
Originating Social Worker must then share the Evaluation Form with their team manager, Service Manager and Service Director.