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    21.    
City Council Regular
Meeting Date: 02/27/2018  

SUBJECT:
SOCIAL MEDIA ENGAGEMENT POLICY
RECOMMENDATION:
  1. Approve the use of Twitter, Facebook, Instagram, and YouTube social media platforms.
     
  2. Approve and adopt the Social Media Engagement Policy to govern the City’s use of social media.
     
  3. Approve an appropriations budget amendment in the amount of $8,200 from the General Fund fund balance to the Community Relations Professional Services account for social media archiving and website link modifications.
BACKGROUND/ANALYSIS:
On September 28, 2010, the City Council discussed the use of social media as another medium for public outreach and communication.  A Social Media Engagement Policy was proposed to govern the City’s use of social media.  Staff recommended adding Facebook and Twitter.  Potential liability issues, the nature of two-way communication and dialog, the desire to push content rather than do unique posts, and the amount of staff time social media would take were discussed.  No action was taken.  Staff was directed to survey local cities to determine how much staff time would be required for posting, commenting, and managing social media accounts.       

On April 26, 2011, the City Council re-considered the use of social media, and after much discussion approved the use of Twitter.  Staff was directed to automatically push content directly from the City website, because it did not require any staff time.    

On January 14, 2014, the City Council approved a temporary Council ad hoc committee for social media and appointed two Council Members.  The ad hoc committee was tasked with developing a Social Media Engagement Policy, evaluating social media and application platforms, and making recommendations on social media use. 

In December 2015, the ad hoc committee discussed and reviewed an app content manager developed by MyCivic apps.  A City of Chino Hills app was developed with interactive report an issue; adopt-a-pet; and picture share features; general City news and announcements;  Emergency, Police, and Road Closure Alerts; a complete parks listing; as well as the development and implementation of all new trails content, including maps and elevation charts.  The app was launched in May 2017. 
 
Social Media Discussion
The City Attorney’s office has advised the City to be cautious of legal ramifications that must be considered when a government agency utilizes social media including:     
  • First amendment issues relating to government restriction on free speech
  • Brown Act open meeting laws and what constitutes a serial meeting
  • What constitutes a public record and records retention requirements
  • Use of public resources
  • Equal access issues
Staff has worked diligently with the City Attorney’s office to draft a Social Media Engagement Policy that mitigates these legal concerns.  There is still no case law to fall back on, and cities must consider whether the benefits of social media use outweigh the risks.  Certainly, policies and procedures can be adopted to reduce the risk, but other than not engaging in social media or not allowing comments and dialogue to occur on social media, we cannot completely remove the risk.  The ad hoc committee recommended that staff develop a policy that takes into consideration these risks, provides guidelines for the governing of social media, and allows the City to engage in two-way, interactive social media use.

The City will designate any approved social media platforms as “limited public forums.”  This is consistent with public agency meetings where Courts have upheld rules of decorum when necessary to prevent a speaker from disrupting the meeting in a way that prevents or impedes the accomplishment of the meeting’s purpose.  Conduct on social media would be monitored in the same way.

GENERAL POLICY
The City’s website www.chinohills.org (or any domain owned by the City) shall remain the City’s primary means of communication via the Internet.  The City’s social media sites may be used to supplement community outreach; emergency communication; to communicate items of interest to a broad audience; and to reach various demographic groups.  Community Relations will act as the Social Media Administrator and generate content, moderate, or otherwise represent the City on City social media sites as part of their assigned job duties.  The City will utilize only one City account per social media platform and will post on behalf of City Departments. 

City social media sites shall be managed in accordance with the Brown Act, the Political Reform Act, the Public Records Act, and the California Election Code. Elected and appointed members of the City of Chino Hills shall not “respond to or comment on,” “like,” “share,” “retweet,” or participate otherwise in any public postings, or use the site or any form of electronic communication to respond to, blog about, or engage in serial meetings, or otherwise discuss, deliberate, or express opinions on any issue within the subject matter jurisdiction of the body. 

City social media sites are also subject to the California Public Records Act.  Any content maintained on a City social media site that is related to City business may be considered a public record and subject to public disclosure.  All postings on City social media sites will be archived and maintained for two years utilizing an automatic digital archiving service.

COMMENT POLICY    
The Comment Policy portion outlines comments that are prohibited and that would be deleted from social media sites.  They include comments that perpetuate discrimination of any of the protected classes of race, religion, color, sex (including gender, gender identity, gender expression, transgender, pregnancy, and breastfeeding) national origin, ancestry, citizenship status, disability, medical condition, genetic characteristics or information, marital status, age, sexual orientation (including homosexuality, bisexuality, or heterosexuality), military or veteran status, as well as any other category protected by federal, state, or local laws; pornographic content and links; solicitations, advertisements or endorsements of any financial, commercial, or non-governmental agency; solicitations or encouragement of Illegal activity; and information that may compromise the safety or security of the public or public systems.     

The City will utilize profanity filters when available to mute profane comments and prevent them from appearing on social media pages. 

CONTENT GUIDELINES
The content of City social media sites shall only pertain to City-sponsored or City-endorsed programs, services, and events.  Whenever possible and appropriate content posted to the City’s social media sites shall contain hyperlinks directing users back to the City's official website for in-depth information, forms, documents and online services necessary to conduct business with the City of Chino Hills.  Staff may “share,” “like,” or “retweet” content from other government, city, agency, or partner social media sites.  City postings and responses to posts will be made during normal weekday business hours.  Posts regarding major road closures and emergency information will occur only after information is confirmed via official sources which can extend the time it takes to complete the social media posting.

The addition of various social media platforms will require additional staff time executing various tasks which include:  planning, communicating with other Departments, graphic design, photography and videography that captures various events and programs, message development, and editing.  Each unique post will require additional time to resize the media for each platform.  Beyond the posting to social media, there will be hours spent on monitoring posts, responding to comments, and analyzing analytics to determine the best strategy to reach various demographic groups.  Facebook reaches an older demographic; Instagram reaches a younger demographic; and Twitter is more of an agency, media, and business audience.  Effective messaging will require time to rework the message for the audience being reached and the character limitations for each platform.         

This work is high visibility and therefore would need to be a priority.  Although, it is difficult to estimate staff time in the absence of numerous social media accounts, we are at the minimum expecting to spend 3 - 4 hours per day managing, responding to, and developing content for the various social media accounts.   
ENVIRONMENTAL (CEQA) REVIEW:
This proposed action is exempt from review under the California Environmental Quality Act (California Public Resources Code §§ 21000, et seq., “CEQA”) and CEQA regulations (14 California Code Regulations §§ 15000, et seq.) because it constitutes an organizational or administrative activity that will not result in direct or indirect physical changes in the environment. Accordingly, this action does not constitute a “project” that requires environmental review (see specifically 14 CC § 15378 (b)(4-5)).
FISCAL IMPACT:
The addition of Facebook, Twitter, Instagram, and You Tube social media accounts will result in the following additional expenses:  $1,000 for “follow us” City website home page design hyperlink additions, $7,200 per year for social media archiving and reporting to meet the public records retention requirements.  Any increased staffing will be evaluated and handled as part of the budget process. An appropriations budget amendment in the amount of $8,200 from the General Fund fund balance to the Community Relations Professional Services account is needed to fund this action.




 
REVIEWED BY OTHERS:
This agenda item has been reviewed by the City Attorney, the Finance Director, and the Community Relations Manager. 
Attachments
022718 SM ENG POL

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