A guide to the revised HCPC standards on social media use for registrants, from CSP senior negotiating officer Kathryn Armstrong
The revised Health and Care Professions Council (HCPC) standards of conduct, performance and ethics come into effect from 1 September. These updates encompass the HCPC standards relating to registrants ‘use of social media. The HCPC has brought in new standards in some areas and have clarified where existing standards extend to registrants ‘social media use.
The HCPC standards apply to all social media use both personal and private and include platforms such as Facebook, X (formerly known as Twitter), YouTube, TikTok, Instagram and WhatsApp.
Historic social media activity is also covered by the standards, even if you were not registered as a physio at the time of the social media activity. Posts can easily be taken out of context or made visible to a wider audience than originally intended but you are ultimately responsible as the author of the post/content. It’s safe to assume that whatever you write online is public and that it can be viewed by anyone.
The HCPC updated guidance advises; ‘It is important that you consider whether any historic social media activity may call into question your compliance with the standards. If it might do, you should take action (for instance, by removing historic social media posts or deleting accounts).’
Discriminatory posts
Section 1.7 of the HCPC standards requires registrants to ensure that their ‘personal values, biases and beliefs do not lead you to discriminate against service users, carers or colleagues’. This may cause concern amongst registrants who perhaps use their social media accounts to express views on wide reaching topics.
Registrants need to be mindful about the impact those views may have on others particularly by those who are the subject. For instance, a post expressing a negative or biased view about a particular religion could cause those who practice that religion to not feel welcome at your practice and the post could therefore fall short of standard 1.7.
What does the HCPC mean by reasonable checks?
Reasonable checks are steps that you can take to check that information is accurate and true. This includes checking sources of information, checking dates and assessing information against your professional knowledge.
Professional boundaries
Under standards 1.8-1.12 members must ensure that they maintain appropriate professional boundaries with service users – including via social media content and contact. Members must ensure that they communicate with patients, patient’s relatives and carers via appropriate methods and keep all contact with service users professional. It’s important to recognise that as a physio you are in a position of trust and that you must maintain professional boundaries at all times. Social media is a valuable tool to promote services and guidance. However, even the most innocent social media contact with service users, especially via personal accounts, could be viewed very differently in the context of a wider allegation around appropriate relationships.
It is not uncommon for service users to search or find you online and social media can blur the boundaries between your personal and professional life. If you are contacted by a patient, their relative or carer via your personal social media accounts the HCPC updated guidance advises that you politely refuse friend requests. If appropriate, say that you cannot mix social and professional relationships. If you want to follow up any contact you receive, consider using a professional communication channel, such as your professional email account.
Where you or your employer wish for you to use social media to promote services, it would be advisable to use a separate professional account for this purpose. If you are employed, you should ensure that you agree with your employer if this is appropriate first.
Spreading misinformation
We have seen a huge increase in the dissemination of misinformation, particularly around public health, and the explosion of social media has made the reach of such misinformation wider than any of us could have anticipated.
The revised standards of conduct, performance and ethics 2.10 and 2.11 require that you must apply the same standards of professionalism to your social media posts as you would when communicating in other ways. Registrants must make reasonable checks to ensure that information that they share on social media is accurate, true and does not mislead the public. Registrants must also ensure that their posts are in line with the duty to promote public health when sharing information on social networking sites.
Many members will be concerned that, given that misinformation is shared so quickly and widely, it is easy for innocent mistakes to happen.
It’s important to recognise that the standards are not intended to stifle broad discussion or to encroach on registrants’ right to free speech under Article 10 of the European Convention on Human Rights. The relevant standards are there to ensure that registrants meet a minimum standard of conduct in relation to their social media use and that the rights and safety of the public are protected. Dissemination of misinformation can impact greatly on public health; you only have to consider the incorrect information relating to Covid-19 which circulated throughout the pandemic in order to appreciate just how damaging misinformation can be.
Members should check that the information they are sharing originates from people or organisations that are trustworthy. If you are unsure, do not post it and make further enquiries. Mistakes happen and anyone can fall for a sophisticated scam. If you realise that you have shared false, inaccurate, or misleading information correct yourself immediately and remove the content.
Members can easily keep to the standards by following three simple rules:
- Assume that everything you say online could be read by anyone, including service users, colleagues and your manager. Privacy settings alone cannot guarantee that something you post will not be shared more widely.
- Think about what you share – is it accurate? Is it discriminatory? Would you be comfortable knowing that a service user had seen it?
- If it’s not there in the first place it cannot get you into trouble – if in doubt, do not post it.
Social media policies and personal/professional accounts
If you are employed, it is important to seek clarity around what your employer’s expectations are in relation to your social media activity. Your employer may have a social media policy or code and it is important that you read this and take action to ensure that your social media activity complies.
Failure to do so could result in disciplinary action being taken against you.
It’s advisable to keep your work and your personal social media activity separate and it is not uncommon for an employer’s policy to stipulate that you should not name your employer on any social media post, platform or account.
Although not having anything identifying your employer in your social media posts/account doesn’t prevent you from falling foul of the HCPC standards, it does go some way to prevent links being made between what you post and your work. If you and your employer agree that you can link your employer to your social media content either by naming them as your place of work or by naming them in posts, the HCPC advise ‘you may choose to include a disclaimer on your profile that your views are your own and that they do not represent the views of your employer or anyone who contracts your services.’
What does the HCPC mean when they say misinformation?
Misinformation refers to inaccurate or false information shared online with or without the intention to cause harm. For example, inaccurate photos, dates or news reports.
Summary
These changes could be concerning for those who use social media both personally and professionally. But we would also reassure members that the standards do not change things a great deal and the areas expanded upon above could already have been encompassed previously in other areas of the existing HCPC standards. It has always been the case, for example, that you should not post anything online that could identify a service user without their prior express consent. Registrants have also always been required to maintain professional boundaries with service users. The revised standards simply make clear to registrants that this extends to social media content.
We spend a lot of time online and social media is a big part of our lives. However, most of the issues that we see with member casework comes from members simply not thinking before they do something; sharing a photo which is inappropriate, commenting or arguing with someone that they do not even know in an online forum, complaining about work or a patient, or corresponding inappropriately with a patient through the convenience of a quick WhatsApp message. Ultimately, taking a short pause to consider how things could look can avoid the vast majority of issues.
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