Guidance

Charities and social media

Published 18 September 2023

Applies to England and Wales

Social media can be a powerful communication tool for charities, to raise awareness and funds and to better engage beneficiaries. It can help charities reach a much wider audience, much more quickly, than traditional methods of communication.

But it can introduce risks:

• its fast pace can increase the risk of posting content that is inappropriate or harmful
• content, once posted, can be hard to undo
• professional and personal lives can overlap, and the line can become blurred

It is important to think about how your charity can use social media effectively to benefit your charity, the risks it may bring, and how you can manage those risks, including by acting reasonably and responsibly to protect your charity.

If your charity uses social media, you are responsible for:

• agreeing and putting in place a social media policy so that you have internal controls that are appropriate and proportionate for your charity’s needs and which are clear to everyone at the charity using social media
• ensuring your social media policy is regularly reviewed to check it is working effectively and fits your charity’s needs
• ensuring your charity’s social media use helps you achieve your charity’s purpose (what your charity was set up to do) and in a way that is in your charity’s best interests
• complying with relevant laws
• ensuring any campaigning or political activity that your charity does on social media complies with the rules on political activity and campaigning
• ensuring your processes help you keep people safe online including any extra considerations when dealing with vulnerable users. Read the “Operating online” section of our guidance on safeguarding

Some trustees may not use social media regularly, or at all, and want to improve their social media knowledge and skills. The government provides a collection of online resources and events to help improve social media literacy and keep people safe online. A number of organisations provide resources to help improve social media skills. For example, the Media Trust provides a resource hub which includes free guides and toolkit.

Set a social media policy

If your charity uses social media, you should have a social media policy.

You should tailor the content of the policy to meet your charity’s needs. How detailed your policy is and how much resource you will need to develop it should match the level of risk presented by how your charity uses social media. It will also depend on the other activities your charity is carrying out.

You should work with employees or volunteers, particularly those who manage your charity’s social media channels, to understand what is required for your charity and to help you develop and implement the policy.

A policy will help you explain:

• your guidelines around the conduct of trustees, staff and volunteers when using social media on behalf of the charity
• how you will engage with the public on social media, for example your rules on moderating comments on the charity’s accounts from those outside the charity
• who is responsible for the day-to-day management of the charity’s social media and who needs to be involved if things go wrong. This includes when trustees need to get involved. At all charities trustees will have a role in setting and reviewing the policy, and in dealing with any significant social media issues or crises. However, at a large charity employees will likely manage the charity’s social media channels day-to-day, whereas at a small charity it may be one or more trustees who have this responsibility
• how your charity uses social media to help deliver your charity’s purpose. Charities can use social media in a variety of ways to further their charity’s purposes. This may be to engage with the charity’s beneficiaries or the wider public on issues directly about what the charity is doing or to highlight its policy positions, or in other ways that support delivery of the charity’s purposes. For example, posting a supportive message about a significant national sporting achievement as part of engaging its followers. Charities should assess any risks of posting about wider issues, be satisfied that it is a proper use of their resources and that the potential benefits outweigh those risks

Make sure that trustees, staff and volunteers responsible for managing the charity’s social media channels are familiar with the charity’s social media policy. You should also make sure that all trustees, staff and volunteers are familiar with the charity’s guidelines on the use of personal social media accounts.

Having a policy will help you set your overall approach to social media that’s matched to the needs of your charity, identifies the processes you need to support the policy, and what to consider if something goes wrong. For example, having a plan about how you would deal with a social media crisis, such as whether you would make a corrective public statement. See the next section of this guidance.

Use our checklist to help you think about what to include in your policy.

A number of organisations provide social media policy templates which may help you develop your own policy. For example, CharityComms has developed a template based on policies from across the charity sector.

If something does go wrong the Commission may take regulatory action. Any action we do take will be in line with our Risk Framework.

Managing potential risks in posting or sharing social media content

People can behave on social media, or respond to criticism they receive on social media, in ways they would not when speaking or writing to the public.

Your social media policy, along with appropriate communications and training for trustees, staff and volunteers responsible for managing the charity’s social media channels, should make clear that your charity should not post or share content which is:

• harmful – what may be harmful to one person might not be considered an issue by someone else, however the UK Safer Internet Centre defines harmful content in simple terms as anything online which causes a person distress or harm
• inconsistent with your charity’s purpose
• not in your charity’s best interests
• in breach of the law

You should ensure that your social media use complies with any relevant laws, for example:

• UK GDPR rules on publishing personal information or data – the Information Commissioners Office (ICO) provides guidance and resources
• privacy (misusing private information or intruding on a person’s right to privacy) - you should consider privacy laws and make sure you have consent, where this is required
• copyright law - if you are using images or artwork on social media. The Intellectual Property Office provides guidance on the use of digital images and photography
• defamation law
• whistleblower protection
• equality and human rights including discrimination, victimisation, harassment, and freedom of expression

You should also be aware of the rules or any codes of conduct of the platforms you are using and the risks associated with spreading false information, particularly if this is shared with intent to mislead.

Publishing certain content can result in a criminal offence, which is a police matter. Examples of criminal offences include communications which constitute hate crime or are malicious, threatening, indecent or grossly offensive.

If you are using social media in riskier contexts, for example with vulnerable individuals or on emotive issues, use our decision-making guidance to help you make a proper consideration and assess the risks. You may also want to consider taking independent advice from a suitably qualified person. Keep written records to help show how you reached your decisions.

Using social media in riskier contexts can attract significant public interest or criticism. The potential for criticism can be mitigated by the trustees ensuring that the charity conducts its activity with respect and tolerance.

Content posted or shared by your charity on social media

Your social media policy should set out who is responsible for managing your charity’s social media accounts and who can post or share content.

It’s also important to have procedures to deal with what happens if there is a breach of the policy or if the content your charity posts or shares risks significantly damaging your charity’s reputation. For example:

• where there has been an apparent breach of the law, the charity should act immediately including by deleting or removing the content if that is possible and reporting the matter to the police or other relevant body, if required. You should be clear about how the breach took place and respond in line with your social media and/or HR policies
• think about whether you need to take corrective action including making public statements. It may be reasonable not to make such statements but you should balance that against any risks of not doing so
• where the breach involved a trustee, you must manage any conflict of interest. For example by asking the trustee involved to leave the meeting where you decide your response
• consider whether to report an incident to the Commission if it has caused significant harm or loss to your charity or the people it helps. Find out more about what we mean by significant harm or loss and about reporting serious incidents

Content posted or shared by trustees, employees or volunteers on their personal social media accounts

Trustees, charity employees and any other individuals have the right to exercise their freedom of expression within the law in their communications, including when using social media. This includes personally supporting a particular political party or (during an election) a particular candidate, something a charity cannot do. However, trustees should be aware of the potential for content posted by individuals in their personal capacity being associated with the charity.

There is no expectation that trustees monitor personal social media accounts.

However, if they become aware of content posted or shared by an individual being associated with and having a negative effect on the charity, they should consider what action to take to protect the charity.

The likelihood of content posted or shared by an individual being associated with and having a negative effect on the charity may depend on who is involved. For example, there may be a greater risk if a Chief Executive of a charity posts or shares on a personal social media account which clearly states their role at the charity or where they blend personal and professional content. In contrast, staff or volunteers with less of a profile online or in their community may represent a much lower risk that any content they post or share will be associated with the charity.

To help manage the risks and any impact on the charity, trustees should share guidelines with their trustees, staff and volunteers, for example through their social media policy. The guidelines should be appropriate for your charity and how it uses social media. They could include some or all of the following:

• the potential for an individual’s personal use of social media to impact on the charity if they choose to disclose their place of work or role at the charity on a personal account
• that individuals who are trustees, are in senior management, or in specialist roles, where they are publicly associated with the charity, should take particular care as personal views may be misunderstood as being the charity’s view
• that individuals should make clear on their personal social media accounts that their views are their own and not the charity’s
• reference to the charity’s HR policies in this area, if relevant
• who they apply to
• the consequences of any breach of such guidelines

If issues do occur, having appropriate guidelines that meet your charity’s needs will help trustees show that they have considered potential risks and have appropriate procedures in place to help manage those risks.

When dealing with any issue concerning a trustee, or a person or organisation connected to them, you must manage any conflict of interest. For example by asking the trustee who posted or shared the content to leave the meeting where you decide your response.

Using social media to engage with the public

Facilitating comments from others on your social media can be a valuable way for the charity to hear directly from and engage with supporters, beneficiaries and the wider public. Different platforms enable different degrees of control and moderation.

But it also means that others can post inappropriate or illegal content on the charity’s social media pages or posts, or through associated groups and forums.

If someone outside the charity has posted content that poses a risk to the charity you should consider:

• what action you should take, based on the nature of the content and what your policy says. This will help you comply with relevant laws and with your own rules
• if you wish to report this to the platform to ban or block users from any further engagement with your charity
• taking legal advice and reporting matters to the police where appropriate. For example, if there is a material risk to the personal safety of you, an employee, volunteer or beneficiary

You may also consider:

• whether your charity would benefit from using tools (or reviewing the tools you currently use) that can help you moderate content. This includes moderating content before publication, managing who can comment, and using settings to hide or delete comments from certain users
• whether relevant staff need training in this area, for example on the use of different tools
• whether staff are getting the support they need from the charity, for example because of their experiences moderating others’ comments or criticisms. CharityComms provide a wellbeing guide for communicators which includes a list of other useful wellbeing resources
• whether the charity should pause, or stop, allowing others to post comments

Social media of organisations connected to your charity

If you work with partner organisations, you should manage the risks of your charity being unduly associated with comments made by them. Read our guidance about working closely with non-charitable organisations.

Engaging on emotive topics

Charities can be involved in issues that provoke strong emotions. Your charity can engage on emotive issues if this is a way of achieving its charitable purpose and is in the charity’s best interests.

You should plan appropriately, for example considering:

• the risks to the charity, including its reputation, and actions you can take to mitigate these. These include informing key stakeholders of your plans and thinking about how the charity’s conduct on social media may help manage potential criticism
• the impact on your resources and staff, for example of receiving a significant number of complaints or negative attention. This should include how you will support staff in case they have to deal with complaints and online abuse
• whether your complaints process is fit for purpose
• other rules or regulations that might apply, for example rules on advertising and broadcasting administered by the Advertising Standards Authority (ASA)

Campaigning or political activity on social media

Charities can use social media to engage in campaigning and political activity.

However, campaigning and political activity by charities are subject to additional rules, set out in our guidance on campaigning and political activity. So, if you are planning campaigning or political activity on social media, as well as considering the points in the previous section, make sure:

• everyone involved knows the rules
• you take extra care around elections

Fundraising on social media

Fundraising on social media has the potential to reach large audiences and can attract wider commentary. This can amplify any criticism a fundraising campaign might attract, and you should take this into account when planning the content of any online fundraising appeal and what social media platforms you use.

The Code of Fundraising Practice applies to fundraising on social media platforms. The Code outlines both the legal rules that apply to fundraising and the standards designed to ensure that fundraising is open, honest and respectful. The Commission expects all charities that fundraise to fully comply with the Code. The Fundraising Regulator regulates charities’ compliance with recognised standards.

Read Charity fundraising: a guide to trustee duties (CC20)

Staying safe online

Adopt processes that help you manage access to your charity’s social media accounts and manage your social media security, including what to do if someone gains access to the charity’s accounts who shouldn’t.

Be aware of others creating fake accounts for you or your charity, which can happen whether or not you are using social media. Inappropriate content can be shared from these fake accounts.

Know how to identify and report them to the social media platform.

Read the ‘Social Media - Protect What You Publish Guide’ and ‘Social Media and how to use it safely’ guide produced by the National Cyber Security Centre, which covers various aspects of cyber security.