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University Response to Adverse Postings on External Website Guidelines

This is not a current document. It has been repealed and is no longer in force.

(1) NOTE: The University Response to Adverse Posting on External Website Guidelines document has been expired effective 10 June 2016. The Media, Social Media and Public Commentary Policy, with the accompanying Social Media Guidelines For Staff, have superseded the above mentioned Guidelines.

Section 1 - Purpose and Context

(2) These guidelines deal with the manner in which the University of Western Sydney might respond to adverse statements or information relating to the University and its staff and students that are posted on external non-University social media and internet sites. The purpose of the guidelines is to provide guidance to:

  1. staff - on when and how to respond to adverse social media commentary on external websites, and what action can be taken; and
  2. students - on using external social media as an avenue to complain about the University, and what action the University may take.

(3) These guidelines do not deal with University generated or controlled social media or internet sites, which are governed by the Web Policy and the Social Media Guidelines.

(4) Social media, such as Facebook and Twitter, gives individuals the opportunity to communicate quickly and broadly including to complain, criticise or make derogatory comment on staff, services or activities of the University, either openly or anonymously. Such negative postings can be relatively minor: such as a one-off rant about perceived poor service or a video parody about the University, but some can be very offensive and possibly unlawful, for example where the posting incites hate towards or harm to an individual, or it misrepresents a person's association with the University.

(5) Complaints and criticisms by students about the University and its staff have always occurred but social media provides a mechanism by which these comments can be dispersed more widely and rapidly than ever before. The University has no effective control over these media and the informality of social media inevitably results in very direct language and a commentary style that often lacks civility and discretion. Postings that find fault with, attack or are derogatory to individuals or groups of staff can be emotionally hurtful to recipients, harmful to the health and wellbeing of staff, and damaging to an individual's reputation.

(6) This does not mean that the University can or should react to all contrary social media commentary. It needs to have a measured approach, finding a balance between being open to scrutiny and providing a safe working and study environment for its staff and students.

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Section 2 - Definitions

(7) Nil.

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Section 3 - Policy Statement

(8) The University policies that are relevant to these guidelines are:

  1. Code of Conduct;
  2. IT Acceptable Use of Resources Policy;
  3. Student Misconduct Rule;
  4. Social Media Guidelines;
  5. Student Code of Conduct; and
  6. Web Policy.
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Section 4 - Guidelines

(9) The University will examine any posting on any external, non-University, social media or other website that it becomes aware of that threatens or incites harm to its staff, students or facilities, or any posting or website that threatens the University's reputation. The University will take action using these guidelines where it believes a posting or a website breaches its policies.

Part A - University and Staff Response to Adverse Postings

External Websites

(10) Staff should not respond to any postings on external social media websites unless authorised by their unit head to do so on behalf of the University.

(11) Where a staff member believes that comments made on an external website contravene these guidelines or breach University policy, the staff member should advise his/her supervisor or unit head. If possible the web page where the posting appears should be printed, and the date and time recorded.

(12) The supervisor or unit head will determine what action to take in accordance with these guidelines, and with advice from the Office of Marketing and Communication.

(13) The unit head will follow these guidelines in determining what action should be taken - refer Part C - Levels of Action.

(14) The University is committed to the safety and well being of its staff and to providing support to staff where necessary, but it is important for staff to understand that the unit head will not always recommend a response or other action on behalf of the University. Staff in front-line or front-of-house activities, such as lecturers and tutors, and Student Central and Campus Safety and Security staff are more likely to be the subject of complaints, and, accordingly, unacceptable social media postings. The University (through the Office of Organisational Development ) will provide training to front-line staff in dealing with social media commentary.

(15) In some cases, depending on the nature of the posting, it will be appropriate for the University to take action, possibly including legal action if the matter warrants it. The University, however, cannot take legal action on behalf of a staff member regarding matters concerning defamation.

UWS Websites

(16) The University's Social Media Guidelines provide advice about posting to an official UWS website, including social media pages, and the responsibilities that staff have when doing so. If an offensive posting is on an official University social media website (that is a website approved in accordance with the Web Policy, Social Media Guidelines and registered on the UWS Social Media Registry), the official moderator is responsible for ensuring that postings do not breach University policy. However, the University, through the Social Media Work Group and the Office of Marketing and Communication can remove (or request to remove) any postings on an official University website if they contravene UWS policy.

Part B - Students Using Social Media to Make Adverse Postings

(17) The Contact Service Centre within the Office of the PVC (Students) monitors official and unofficial social media sites for comments about the University, both good and bad. It understands that students or potential students do not always have a satisfactory experience in some or all of their interactions with the University and/or its staff, and it recognises that students may use social media sites to express their satisfaction or dissatisfaction. The University is open to feedback about its staff and services, and has a complaint process in place but some comments on social media and other websites go further than just raising an issue of complaint. Many negative comments are simply a response to frustrations that a student has about not receiving the level of service, professionalism or expertise that they expected, or are in jest, designed to make fun of the University, its staff or other students. Sometimes these posts can be rude or discourteous. However, some comments and postings are obscene, abusive, and/or urge others to target and threaten harm to staff of the University. These types of postings are unacceptable and they do a disservice to the individual that posts them, as well as to the University's reputation.

(18) People using social media and other websites must be mindful of the consequences of making postings that overstep the boundaries of reasonable complaint or frustration. Firstly, such postings could breach the University's policies and could lead to misconduct proceedings being initiated against a student or students. Secondly, postings are traceable even if removed at a later time or made anonymously. If the matter is serious enough the University and other authorities, such as the police, will investigate.

(19) Some people mistakenly treat social media postings as if they are private and as if they are communicating with friends only or, at least, with people with similar interests. In many cases, however, they are not. A posting designed only to be made known to a select group can be re-posted, hyperlinked, emailed and similarly passed on to a large number of unknown people. The original composer cannot control the distribution and has no way of knowing its reach. Additional problems appear because the posting or video is then taken out of context. For example, what was designed to be humorous in the context of one site can appear as humiliating or damaging to individuals on another.

(20) Another matter of concern to the University is where students or other members of the University community, such as alumni, misrepresent their association or affiliation with the University.

(21) The University will take action using these guidelines where it believes a posting or a website breaches its policies - see Part C - Levels of Action.

Part C - University Action on Adverse Postings

(22) The University has developed four levels of action in responding to unacceptable social media postings or other activity on external websites.

1. Monitor

(23) There are circumstances where it is appropriate or necessary for the University to require no response to a posting on an external social media or other website. For example, if the matter is of a relatively minor nature and/or the person posting the comment is using a pseudonym that is unrecognisable, the University may not respond. In fact, it is sometimes better for the University not to respond as doing so may create a negative reaction and inflame the matter. Students and other members of the University community should have the opportunity to talk freely about their experiences. When a staff member responds on behalf of the University, even if it is to provide helpful information or to correct an assertion, the commentators may see this as an invasion into their space.

(24) At times, the unit head may consider it appropriate to let the conversation run its course. Social media is often focussed on the current and immediate, and topics fall as swiftly as they rise and are replaced by a new discussion. Social media can also be self regulating. Where, for example, other users believe a commentator has overstepped the mark they will rebuke that commentator.

(25) The University will continue to monitor such discussion. A staff member should raise any matters of concern with his/her supervisor or unit head in the first instance.

2. Contact

(26) Where the University believes that a posting or website has the potential to breach University policy, it may contact the author and/or the website to request that the material be removed. At times, people are unaware that their posting could contravene UWS policy and lead to more serious action being taken by the University or the individual concerned. The relevant unit head will discuss with the Office of Marketing and Communication the appropriate course of action to take.

(27) If the posting is believed to be by a student, the Pro Vice-Chancellor, Students or nominee, or Dean is the appropriate person to make contact. Such contact will be made in consultation with the relevant unit head, and the Office of Marketing and Communication. The Pro Vice-Chancellor, Students or nominee will notify the author of the positing that there is the potential for a breach of policy to occur and the consequences of that. The Pro Vice-Chancellor, Students, or nominee or Dean may also invite the author to attend a meeting to discuss the matter.

(28) On other occasions, it will be appropriate for the unit head to authorise a response to a posting. It may be, for example, to provide some advice on process, to clarify or apologise for a problem that has arisen, to suggest alternative methods of making a complaint or to try to resolve an issue. Where it is considered appropriate to respond to a posting, only the relevant unit head is authorised to do so. Any response should be carefully considered and advice can be sought from the Pro Vice-Chancellor, Students, Office of Marketing and Communication, or Office of Legal Counsel (OLC).

(29) Where the posting is anonymous, the University (through the Office of Marketing and Communication ) may request that the website owner remove the content, and may take action to determine the real name of the author.

3. Initiate Misconduct

(30) Where a posting on a social media or other website contravenes University policy and the University believes the matter warrants it, the University will take action under the relevant policies. For students, this means that the processes within the Student Misconduct Rule will be initiated. For staff, this means that the processes for misconduct within the relevant staff agreement will be followed.

(31) The relevant unit head may seek advice from the Office of Governance Services, the Pro Vice-Chancellor, Students or nominee, Office of Marketing and Communication, Office of People and Culture or Office of Legal Counsel in undertaking such action. The University (through the Office of Marketing and Communication ) will also make contact with the author or website owner to request that the material be removed.

4. Contact the Police

(32) The University will not tolerate any posting on a social media or other website that threatens or incites harm to its staff, students or facilities. Such threats are taken seriously and will be referred to the police, even if the posting is anonymous.

(33) Where such threats are made, the Director, Campus Safety and Security, should be advised immediately. The University will not respond to any posting of this manner unless the Director, Campus Safety and Security authorises a response. If the posting is on a UWS site, the Director, Campus Safety and Security, will liaise with the Social Media Work Group about arranging for such postings to be removed. If the posting is on an external website action will be taken to identify the person/s making the threat.

(34) Where a posting misrepresents an individual, business or other entity's relationship with the University the relevant Deputy Vice-Chancellor will seek legal advice on behalf of the University about what action to take against the owner of the website or the person/s making the posting.

Part D - External Information

(35) There are many websites that can provide guidance on helping determine what is and what is not appropriate use of social media:

  1. Top 11 dos and don'ts of online reputation management (from reputation.com)
  2. Stay Smart Online (Australian Government)
  3. Privacy Topics - Internet, Communications and Other Technologies (Office of the Australian Information Commissioner)