Medical College of Wisconsin Affiliated Hospitals, Inc.
SOCIAL MEDIA POLICY
Social media may be used by housestaff employed by The Medical College of Wisconsin Affiliated Hospitals, Inc. (MCWAH). MCWAH recognizes that the use of social media can be a positive experience and supports the use when beneficial to advancing the mission of graduate medical education. These guidelines are intended to ensure compliance with legal and regulatory requirements as well as patients’ rights to privacy and confidentiality. Social media includes items such as blogs, podcasts, discussion forums, and social networks.
Blog: Short for “Web log,” a site that allows an individual or group of individuals to share a running log of events and personal insights with online audiences.
Housestaff: Residents and fellows employed by MCWAH.
Electronic Media: Non-computing devices, e.g., flash memory drives, CDs, DVDs, tapes, hard disks, and any other interchangeable, reusable, and/or portable electronic storage media on which electronic information is stored.
Podcast: A collection of digital media files distributed over the internet for playback on portable media players and personal computers.
Protected Health Information (PHI): Any individually identifiable health information, whether oral, written, electronic, transmitted, or maintained in form or medium that:
Is created or received by a health care provider such as the Medical College of Wisconsin, an affiliated hospital, a health plan, or a health care clearinghouse; and
Relates to an individual’s past, present, or future physical or mental health condition, health care treatment, or the past, present or future payment for health care services to the individual;
That either identifies an individual (for example, name, social security number or medical record number) or can reasonably be used to find out the person’s identity (address, telephone number, birth date, e-mail address, and names of relatives or employers).
Social Media: Includes, but is not limited to, social networking sites, discussion forums, personal web pages, personal space provided by internet providers, and internet presence including sites such as Facebook, YouTube, LinkedIn, Twitter, and blogs which make available personal views to the general public.
This policy applies to Housestaff using social media while at work. It also applies to Housestaff use of social media when away from work when his or her relationship with MCWAH or its affiliated institutions is identified, known, or presumed. It does not apply to content that is non-health care related or is otherwise unrelated to MCWAH, its affiliates or to their patients.
When using social media Housestaff are expected to be professional and ethical, keep patient information confidential and private, and restrain from harassing or discriminatory statements or behavior towards others as is required by MCWAH’s policies and MCWAH’s Housestaff Handbook. Additionally, Housestaff must comply with the policies of MCWAH’s affiliates regarding confidentiality and privacy of patient information, compliance, the use of their electronic medical records and the use of their electronic equipment.
Housestaff are required to comply with the MCW Social Media Policy available at http://infoscope.mcw.edu/CorporatePolicies/Social-Media.htm.
Personal, Non-Official, Use of Social Media
Housestaff may not disclose any confidential or proprietary information of or about MCWAH, its employees, or its affiliates including but not limited to business and financial information, represent that they are communicating the views of MCWAH, or do anything that might reasonably create the impression that they are communicating on behalf of MCWAH.
Housestaff may not use or disclose any patient identifiable information of any kind on any social media without the written permission of the patient. Even if an individual is not identified by name within the information you wish to use or disclose, if there is a reasonable basis to believe that the person could still be identified from that information, then its use or disclosure could constitute a violation of the Health Insurance Portability and Accountability Act (HIPAA).
Housestaff may not use social media to establish a personal relationship with a patient or with a former patient for 2 years after terminating services or for 2 years after the patient reaches the age of majority.
The use of MCWAH’s or its affiliates’ logos, trademarks and intellectual property is not allowed.
Threatening or disparaging statements against MCWAH, it’s employed Housestaff, staff, or affiliates should not be made.
General Guidelines to Follow for Personal Use of Social Media
Do not discuss patients even in general terms.
Assume anything put online could be seen by anyone. Do not post anything you would not want to turn up in the media.
Take particular care when replying to people in real-time venues like Twitter or texting. You don’t have to respond right away, and if you have any doubt at all as to the recipient of the information, don’t respond at all.
Don’t mix personal and professional lives. Don’t “friend” patients on Facebook or other social media websites if your only relationship with the person is professional.
Check privacy settings on social media websites monthly because they can change from time to time.
The original policy was approved at the MCWAH Graduate Medical Education Committee on July 16, 2012.
MCWAH Institutional Policy Professional Behavior, http://www.mcw.edu/GME/IP/IPMainPage/ProfessionalBehavior.htm
MCWAH Housestaff Handbook, http://www.mcw.edu/GME/Resources/Housestaff-Handbook.htm
MCW Social Media Policy available at http://infoscope.mcw.edu/CorporatePolicies/Social-Media.htm.
Wis. Admin. Code, § Med 10.02(zd).