Purpose
This Social Media Policy ("Policy") establishes guidelines for the establishment and use by the City of Norwalk ("City") of Social Media Sites as a means of conveying information to members of the public.
The intended purpose of City Social Media Sites is to disseminate information from the City about the City's mission, meetings, activities, and current issues to members of the public.
The City has an overriding interest and expectation in protecting the integrity of the information posted on its Social Media Sites and the content that is attributed to the City and its officials.
Definitions
"Social Media Sites" means content created by individuals, using accessible, expandable, and upgradable publishing technologies, through and on the internet. Examples of social media include, but are not limited to, Facebook, Twitter, lnstagram, YouTube, Google Business Profiles, and Linkedln.
"City Social Media Sites" means Social Media Sites which the City establishes and maintains, and over which it has control over all postings, except for advertisements or hyperlinks by the Social Media Site's owners, vendors, or partners. City Social Media Sites shall supplement, and not replace, the City's standard methods of communication.
"Post" or "posting" means information, articles, pictures, videos or any other form of communication posted on a City Social Media Site.
General Policy
The City's official website at www.Norwalk.org (or any domain owned by the City) will remain the City's primary means of internet communication.
No City Social Media Sites shall be established for the City Council, Commissions, Committees, or Boards. The establishment of City Social Media Sites is subject to approval by the City Manager or their designee. Upon approval, City Social Media Sites shall bear the name and/or official logo of the City.
Content on City Social Media Sites is subject to oversight by the City's Communications & Public Affairs Department Director or their designee.
City Social Media Sites shall clearly state that such sites are maintained by the City and that the sites comply with the City's Social Media Policy.
City Social Media Sites shall link back to the City's official website for forms, documents, online services and other information necessary to conduct business with the City whenever possible.
City Social Media Sites shall be managed consistent with the Brown Act. Members of the City Council, Commissions and/or Boards shall only use social media to answer questions, provide information to the public, or solicit information from the public for matters within the subject matter jurisdiction of the agency as required by Government Code Section 54952.2(b)(3).
The City reserves the right to terminate any City Social Media Site at any time without notice.
City Social Media Sites shall comply with usage rules and regulations required by the site provider, including privacy policies.
The City's Social Media Policy shall be displayed to users or made available by hyperlink.
All City Social Media Sites shall adhere to applicable federal, state and local laws, regulations and policies.
City Social Media Sites are subject to the California Public Records Act. Any content maintained on a City Social Media Site that is related to City business, including a list of subscribers, posted communication, and communication submitted for posting, may be considered a public record and subject to public disclosure.
Employees representing the City on City Social Media Sites shall conduct themselves at all times as a professional representative of the City and in accordance with all City policies.
All City Social Media Sites shall utilize authorized City contact information for account set-up, monitoring and access. The use of personal email accounts or phone numbers by any City employee is not allowed for the purpose of setting-up, monitoring, or accessing a City Social Media Site unless necessary to use a certain Social Media Site and approved by the Communications & Public Affairs Department Director or their designee in writing.
City Social Media Sites may contain content, including but not limited to, advertisements or hyperlinks over which the City has no control. The City does not endorse any hyperlink or advertisement placed on City Social Media Sites by the Social Media Site's owners, vendors, or partners.
No communications made with the City through any City Social Media Sites shall be deemed to constitute public comment or legal notice to the City or any of its agencies, officers, employees, agents, or representatives where notice to the City is required by any Federal, State, or local law, rule, or regulation. Any such comment or notice shall be submitted to the City as ordinarily prescribed, including any established City process for submitting comments online for a public hearing or City Council or commission hearing and not through City Social Media Sites.
The City reserves the right to change, modify, or amend all or part of this policy at any time.
Content Guidelines
The content of City Social Media Sites should only pertain to City-sponsored or City-endorsed programs, services, and events. Content includes, but is not limited to, information, photographs, videos, and hyperlinks.
Content posted to the City's Social Media Sites must contain hyperlinks directing users back to the City's official website for in-depth information, forms, documents or online services necessary to conduct business with the City of Norwalk, whenever possible.
City officials or employees posting content on City's Social Media Sites must ensure that City has full permission or rights to any content posted by the City, including photographs and videos.
Postings by City officials or employees on City Social Media Sites shall be made during normal business or employee's shift hours. After-hours postings shall only be scheduled ahead of time or made with approval of the City's City Manager, Communications & Public Affairs Department Director or their designee.
Any employee authorized to post items on any of the City's Social Media Sites shall review, be familiar with, and comply with the Social Media Site's use policies and terms and conditions.
Any employee authorized to post items on any of the City's Social Media Sites shall not express his or her own personal views or concerns through any official City postings. Instead, postings on any of the City's Social Media Sites through the official City account shall only reflect the views of the City.
Postings must contain information that is freely available to the public and not be confidential as defined by any City policy or state or federal law.
Postings may NOT contain any personal information, including but not limited to any personal information such as home addresses, personal phone numbers, or social security numbers without prior written consent, except for the names of employees whose job duties include being available for contact by the public.
Postings to City Social Media Sites shall NOT contain any of the following:
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Comments that are not topically related to the particular posting being commented upon;
- Comments in support of, or opposition to, political campaigns, candidates or ballot measures;
- Profane language or content;
- Content that promotes, fosters, or perpetuates discrimination on the basis of race, creed, color, age, religion, gender, marital status, or status with regard to public assistance, national origin, physical or mental disability or sexual orientation, as well as any other category protected by federal, state, or local laws;
- Sexual content or links to sexual content;
- Solicitations of commerce;
- Conduct or encouragement of illegal activity;
- Information that may tend to compromise the safety or security of the public or public systems;
- Content that violates a legal ownership interest of any other party;
- Defamatory statements; or
Threats of violence or injury to any person, property, or organization, or the incitement of others to such violence.
These guidelines shall be displayed to users or made available by hyperlink on all City Social Media Sites. Any content removed based on these guidelines must be retained, including the time, date and identity of the poster, when available.
Except as expressly provided in this Policy, accessing any Social Media Site shall comply with all applicable City policies pertaining to communications and the use of the internet by employees, including email content.
Content Management
The City is committed to serving the online community in a civil and unbiased manner.
All comments or postings related to the City Social Media Sites will be subject to monitoring by the City's City Manager, Communications & Public Affairs Department Director or their designee.
Any content by a member of the public sent to, published, or posted on or through City Social Media Sites, including without limitation a post or a response to any City post or comment, is the opinion of the commenter or poster alone, does not imply endorsement of or agreement by the City, and the City disclaims liability for any such content. Generally, posts from the public may not be regulated based on their viewpoint, even if negative or critical of the City or an official.
The City reserves the right to restrict or remove any content that is deemed by the City to be in violation of this Social Media Policy or any other applicable law. Any City employee, volunteer, or official who finds content on or through City Social Media Sites that is potentially inappropriate or inconsistent with this Policy will notify the City Manager or their designee, who will consult with the City's legal counsel for direction on further handling of the potentially inappropriate or inconsistent content to ensure compliance with the Policy. The City disclaims any and all responsibility and liability for any materials that the City deems inappropriate for posting that cannot be removed in an expeditious and otherwise timely manner.
For all City Social Media Sites, the City shall post the following disclaimer on the respective City Social Media Site page: "The City of Norwalk reserves the right to restrict or remove any postings or comments that violate the City's Social Media Policy, which can be found on the City's website."
Any content removed based on this Policy must be retained by the City per the City's record retention schedule and will include the time, date and identity (including username or screenname) of the poster, when available.
The City may block specific users, but only to the extent that such users' comments are determined by the City to repeatedly be defamatory, obscene, or for purposes of posting spam, promoting illegal activity, or soliciting commerce. In no event shall a user be blocked for disagreeing with or providing a contrary opinion or point of view.
Personal Social Media Accounts
Any use of a personal accounts on Social Media Sites to “conduct City business” are subject to the same legal limitations as using official City accounts.
City officials shall avoid conducting any City business on non-official social media accounts including commenting on any City business, or posts by other City officials or on the City Social Media Sites.
Commentors on a City official’s personal social media account are protected by the First Amendment if the account is deemed to be used to conduct or comment on City business. Removing comments or blocking users may result in a violation of the user’s First Amendment rights.
City recommends that any officials or employee wishing to post on City Social Media to conduct business or engage the public create separate official and personal accounts and avoid posting any City-related content on or from their personal accounts.
City also recommends that personal accounts be made private rather than public so that the City official or employee may control the users in their network in addition to who may view the City officials’ or employees’ posts or comments.
