Policy 

Institutional social media and social network/messaging accounts for university and departmental marketing and communications purposes are important methods to reach key stakeholders and audiences. The terms “social media” and “social network/messaging” refers to online communication platforms and services that allow internet users to create, publish, share content, and communicate with audiences to help raise brand awareness, drive engagement, and inspire advocacy. When using social media for university marketing and communications purposes, individuals must be conscious of security, compliance, brand, and reputation and conduct themselves in alignment with university policies.

This policy has been designed for marketing purposes only, and it is not to be viewed as an academic policy. Miami University recognizes the use of social media by employees as part of their official duties to connect and engage the Miami community. This document contains policies, procedures, requirements, and resource information to help employees establish, maintain, manage, and monitor official Miami accounts to encourage engagement while providing parameters to protect the university and its reputation.

Authorization and Authority

This policy applies to all approved official social media accounts used to speak on behalf of Miami University and its divisions, colleges, departments, centers, and organizations. This policy also applies to accounts that represent specific positions at the university (e.g., Dean of Students, Vice President for IT); however, it does not apply to the personal accounts for the individuals in those roles.

This policy does not apply to accounts that post on behalf of student organizations, clubs, or intramural activities.  However, Miami maintains the right to request that student-operated accounts disclose the proper relationship to the institution and appropriate branding representation.

Definitions

This section clarifies the terms used throughout this document for the clarity of non-marketing and communication professionals:

Community manager 

The person who has the authority and accountability to manage a division/department/unit’s social media presence.

Miami community

An overarching term to represent all the audiences that makeup Miami University, including prospective students, current students, faculty, staff, alumni, donors, legislators, and localities.

Social media platforms

Platforms is an overarching term to discuss all social media sites broadly and applications found online. Popular social media platforms include Facebook, Twitter, Instagram, TikTok, and similar sites.

Social media accounts

Accounts, pages, handles, or online representations of Miami official departments, organizations, and positions on social media platforms.

University position accounts

Position accounts are representations of Miami University positions that hold official communication authority and the ability to speak on behalf of the institution.

Social messaging and social media

These apps are more focused on engaging in chat-style functionality and broadcasting capabilities.

Account Creation

Creating a department or unit’s social media channel is a long-term engagement strategy. Departments/units must receive approval from University Communications and Marketing before creating accounts that represent Miami University. In addition, departments/units must review and be familiar with all policies, requirements, procedures for Miami University’s social media accounts, and submit a completed social media/social messaging/network application form.

Community Managers may not open accounts before approval from this process is provided. Failure to adhere to policy standards could result in the deletion of the account and/or denial of the application.

Account Management

Continual oversight of the departmental and unit accounts, access, security, and content management must be planned before setting up an account. Community managers must follow the proper procedures for the continued use and success of their accounts.

Account ownership 

Social accounts created for official communications on behalf of the university should be easily managed and accessible by at least two full-time employees. Each account must have at least two full-time employees with equal administrative rights. When the account is only accessible by user name and password, at least two full-time employees should have the credentials to access the account. Student employees, interns, and graduate assistants are not eligible for account ownership. At no point should a student employee, intern, or graduate assistant be the sole authority and operator of an official social account without the direct supervision and accountability of a Miami University employee.

Departmental access

Official accounts should be easily managed and transferable between full-time employees when needed. This means all accounts and handles should be registered with a departmental email address. This email address must be accessible by a minimum of two users who are full-time Miami University employees. University social media accounts should never be tied to an individual employee’s email address or a personal email address.

University Communications and Marketing access

As with other university communications tools, departmental and organizational social media and social network/messaging accounts fall under University Communications and Marketing’s responsibility. Therefore, all departmental and organizational social account credentials must be shared with and securely stored by University Communication and Marketing. Community managers can securely send UCM their account credentials through the social media password form on the UCM website.

Multiple users accessing accounts

Departments and organizations may employ any number of individuals to contribute to the management of their social accounts. This may include additional faculty, staff, student employees, and/or interns.

Account transitions

If the community manager is leaving the department, division, or university, account transitions will need to occur before the last week of the employee’s tenure. Upon the departure of any authorized user, the current, interim, or community manager will be responsible for removing access from accounts and updating each social account’s password. The current, interim, or new community manager will follow the credential reporting procedures to provide updated passwords.

Termination

If a community manager is being terminated, it is the responsibility of the community manager’s supervisor to communicate with University Communications and Marketing staff before the termination date. This will allow for the successful transition of the accounts to another full-time employee. It is also the responsibility of the second full-time employee of the account to submit the account transition form and account credential form to University Communications and Marketing.

Account Inactivity and Abandonment

It is the role of a community manager to ensure consistent and engaging content is produced for their accounts. To ensure the best representation of Miami University to the public, University Communications and Marketing will

regularly review all social accounts for periods of inactivity of 90 days between posts and/or abandonment of more than 120 days of non-posting. When an account is found to be inactive or abandoned, University Communications and Marketing reserves the right to pause, hide, or delete the account in question. University Communications and Marketing will make every attempt to mitigate an account removal with the appropriate department or organization due to inactivity before seeking the removal of the account on a platform. When an account is paused, hidden or deleted, the community manager must resubmit a request for account creation to University Communications and Marketing before an account will be reactivated.

Account Branding

All official Miami University social media accounts must follow Miami’s identity standards outlined in full within the Miami Visual and Editorial Standards Manual on the University Communications and Marketing website.

Miami’s colleges, divisions,  programs, departments, and business units must use official university social media icons, naming conventions, disclosures, and account structures on all official social media accounts to connect with the university; differentiate from competing accounts; and establish uniform quality, credibility, and user experiences.

Student sports clubs and organizations have limited ability to use Miami branding within their accounts. These capabilities can be found on the Miami Visual and Editorial Standards Manual on the University Communications and Marketing website.

Other social platforms customizations and branding opportunities

Social media and social networking/messaging are ever-evolving. As new platforms rise and gain popularity, University Communications and Marketing will provide our campus partners with guidance on using emerging platforms’ best branding opportunities. See the University Communications and Marketing website for additional details.

General Marketing and Communications

Social messaging and audio accounts, such as Clubhouse, Fireside, Snapchat, WhatsApp, and WeChat, are being used to engage various Miami University populations. When engaging in this medium of communication, community Managers are to remember the rules and policies associated with electronic communications. Community Managers should refrain from providing personally identifiable information of a student or protected information (e.g. HIPAA, FERPA). Community Managers also have the responsibility of reporting information related to any Title IX disclosures.

Crisis Communications

In a crisis, all official content will come from the @MiamiUniversity main social media and social network/messaging accounts, handles, and pages. Other University social media accounts may only share/repost from official information. Reports outside of the university are not considered official communications (i.e., external news outlets).

Situations in which crisis communications procedures are enacted vary based on the scope of legal action, brand perception/reputation/reception damages, or other public relations rationale. Examples of crisis communications can include but are not limited to protests, inappropriate communications, a credible threat or actions made by a Miami community member, social unrest, petitions, or otherwise acts of negative communications and actions that should be managed by communications and public relations professionals.

Official division, departmental, and organizational accounts will refrain from posting standalone announcements, releases, and statements of any type on social media unless the wording has been approved by the crisis management team and University Communications and Marketing. Failure to follow crisis communications guidelines and standards will result in the removal of the department or organization’s social media accounts.

Policies and Laws Related or Connected to Social Media

When engaging in any social media activity as part of official duties at Miami University, employees are governed by the same policies that govern all other electronic communications. Employees must not violate university computing, privacy, IT, FERPA, NCAA, intellectual property, branding, freedom of speech, or other local, state, or federal policies and laws.

This section applies to the disclosure of protected information while engaging in social media activity:

• During employment at or while conducting activities for Miami University
• As part of the employee’s official duties

Such employees/individuals must follow all applicable local, state, and federal laws (i.e., FERPA, NCAA, and HIPAA) as well as policies found in Miami’s faculty and staff handbooks and the Brand Identification and Standards manual. Any content that violates any of these or contains/leads to a student’s private or personal information is strictly prohibited and shouldn’t be posted by employees or others using the account. Violations must be reported immediately to University Communications and Marketing.

First Amendment Speech

As a public institution, Miami University respects freedom of speech and cannot violate an individual’s First Amendment rights; therefore, posts and comments on Miami University’s official accounts may not be removed unless users share protected information, or the content is otherwise illegal. Community managers must obtain approval from University Communications and Marketing and the Office of General Counsel before removal.

Under the First Amendment, content on a typical, open social media platform (i.e., the Miami University official Facebook page) cannot be limited based on the content of the speech/expression - except for posts that break laws, that materially interrupt the work and discipline of the University, or interfere with the opportunity of other students to obtain an education.

Academic Freedom

Academic Freedom is a core principle of faculty to develop research, manage classrooms, and benefit society through education and thought. Academic Freedom is not a legal standing, thus giving the administration the responsibility of defining the line between the increasing online blending of professional and personal communications. As such, Miami holds the stance that faculty can speak on the research and work of the position they hold through official departmental and position-based accounts in which university capital, resources, and time are used to develop and publish communications. Personal communication regarding work conducted using university resources may occur on an employee’s personal social accounts; however, when the employee references Miami University or references Miami’s websites, articles, or other owned online properties, employment by Miami should be disclosed, as stipulated by FTC disclosure guidelines. This is also made clear in the Miami University Academic Freedom policy stating, “faculty members should at all times be accurate, should exercise appropriate restraint, should show respect for the opinions of others, and should make every effort to indicate that they are not speaking for the institution.”

Public records

Miami is a public institution. Information created and stored on university social accounts may be subject to Ohio public records law and public records requests. Community managers seeking to remove posted information from social accounts must contact University Communications and Marketing before removal. This requirement applies to all posted information, whether posted by the division/department or by external parties/users but does not apply to the immediate removal of unit-created content due to typographical or other posting errors.

On a closed platform (i.e., a specific Facebook group), the account administrator cannot limit the content (what is said) of the social post but can determine:

• Who can be added to the group
• Who can post
• How long posts can remain active
• Number of times a person can post
• The topics discussed

Hiding comments or blocking users

While disabling, hiding, removing, blocking, or reporting comments and users’ features are available with social platforms, community managers cannot do so without prior authorization from University Communications and Marketing and the Office of General Counsel. If you believe that a comment or user should be addressed, send a screenshot and link to socialmedia@miamioh.edu.

Likeness/right of publicity laws

When using imagery of students, faculty, staff, or other members of the Miami University community, it is advised to request character/likeness authorization before distribution. Authorization can be as simple as asking a student via a recorded method for authorization to use their likeness. A long-form example to request permission can be seen below:

I hereby authorize Miami University (University) and those acting under its authority to: (i) record my likeness and/or voice on a video, audio, photographic, digital, electronic, or any other medium; (ii) use my name and biographical material in connection with such recordings; and (iii) use, reproduce, exhibit, and/or distribute my name, biographical material, and such recordings in any medium (e.g., print publications, video, internet, social, etc.) for promotional, advertising, educational, and/or other lawful purposes. I release and waive any claims or rights of compensation or ownership regarding such uses and understand that all such recordings shall remain the property of the University.

FERPA

Protected, confidential information is covered by privacy laws, especially FERPA: “The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C § 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.”

Those who conduct social media activities for Miami University must not engage in any conversations or share any information regarding student records. Some examples of student records include names, admission status, GPA, Social Security numbers, and any other information covered by FERPA. If students request assistance via social media, employees can direct them to a secure discussion platform such as phone, email, or a link for more information.

HIPAA

Protect confidential media records as specified by HIPAA. “The privacy rule protects all ‘individually identifiable health information held or transmitted by a covered entity or its business associate, in any form or media, whether electronic, paper or oral.” Examples of protected information include: “…the individual’s past, present, or future physical or mental health conditions, the provision of health care to the individual, and that identifies the individual or for which there is a reasonable basis to believe it can be used to identify the individual.”

NCAA

Miami University employees and individuals must abide by NCAA regulations when interacting and communicating on social media platforms. Employees may not contact (i.e., tweet or friend/like) prospective student-athletes on social media until after they’ve signed a National Letter of Intent with Miami University. Please contact Miami University’s Office of Intercollegiate Athletics for any clarification or questions related to the policy.

Business transactions

The University does not endorse or use any social network or social media platform as a secure means of communication for online business transactions or matters involving personal information exchange. The University will not ask for, nor may an individual send, credit card or payment information, classified information, privileged information, private information, or information subject to non-disclosure agreements via any social network internet communication service or social media platform.

Copyright and fair use

Respect copyright law. “Copyright, a form of intellectual property law, protects original works of authorship including literacy, dramatic, musical, and artistic works, such as poetry, novels, movies, songs, computer software, and architecture. Copyright doesn’t protect facts, ideas, systems, or methods of operation, although it may protect the way these things are expressed.” Fair use allows portions of certain works to be used without consent under specific situations; however, “The safest course is always to get permission from the copyright owner before using copyrighted material.”

User-generated content (UGC) falls under copyright and fair use laws. Permission from the user does not give the institution, department, or organization unlimited right to use the content.. If the department/organization/institution wishes to use the UGC beyond the platforms and timeframe agreed upon by the user, the department/organization/institution should communicate and define the platforms/mediums the asset will be used, as well as the planned timeline the asset will be employed to the owner for permission.

Linking to the source material

When creating content for your social platforms, if a piece of content comes from published works or another source, the community manager must provide credit to the content author and link to the source material when applicable. Linking to the source material must be readily visible and accessible without having to navigate beyond the post.

Diversity, equity, and inclusion (DEI)

This social media policy will be updated annually according to a DEI strategic plan. These updates will look to make university social accounts a space where our Miami community can feel invited, represented in a meaningful way, and inclusive to all our minority representative populations.

Political activities and political speech

Miami University does not support one political party or agenda over another. Social media can educate our community about civic engagement, democracy, and citizenry; however, as an institution, we are apolitical and this type of content could be misunderstood as institutional alignment to a political party. When communicating on behalf of the university, it is the community manager’s responsibility to review the content for political speech-language and always communicate impartiality.

Furthermore, Miami accounts cannot endorse or denigrate any political party or politician both active and retired. If you are unsure if the post falls within political speech, the best course is not to post.

Accessibility

Miami University is an institution for all students and communities with various abilities and needs. Consequently, accessibility of your social channels is required when engaging in the platforms on behalf of Miami; including but is not limited to the following descriptors:

• Alternative text descriptions for images
• Captioning of videos
• The context for Animated GIFs
• CamelCase Hashtags (#CapitalizingTheFirstLetterInEachWord)

Additional accessibility documentation can be found on each major social platform. It is the responsibility of the community manager to be aware of each platform's accessibility capabilities and to utilize the functionality when necessary.

Record retention

As a government agency, record retention laws are in place for social media accounts representing Miami. For the State of Ohio, specific documents or records will need to be retained. Records for social will need to periodically be pulled from the platform and stored in a secure manner that can be readily accessed if requested. For details of the retention schedule and types of content that needs to be retained, visit General Counsel Records and Retention.

Terms of use

Upon creating the social media accounts, the community manager must accept and abide by the terms and conditions of the social media platform. Community managers may not agree to the terms and conditions on behalf of the institution upon account creation if the account has not been approved by the University Communications and Marketing account creation approval process.

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Related Form(s)

Not applicable.

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Additional Resources and Procedures

Not applicable.

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FAQ

Not applicable.

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Policy Administration

Next Review Date

7/1/2024

Responsible Officers

• Director of Digital Marketing
• Senior Director of Marketing and Communications
• Vice President and Chief Marketing and Communications Officer

Legal Reference

Not Applicable.

Compliance Policy

No

Recent Revision History

New July 2022

Reference ID(s)

N/A

Reviewers

• Vice President & Chief Marketing and Communications Officer