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Social Media Policy

ORMC/CRMC recognizes that social networking (such as personal websites, blogs, Facebook, MySpace, Twitter, online group discussions, text messaging, message boards, instant messengers, chat rooms, etc.) are used by many of our employees. Visiting such sites are not appropriate work time activities unless required by the scope and responsibilities of an employee’s job. Such activities, if engaged in, must be limited to nonwork time (including breaks and meal periods) and must comply with the ORMC/CRMC policies governing the proper use of the Internet, e-mail, and computer usage. ORMC/CRMC respects the right of our employees to maintain a blog or post a comment on social networking sites. However, ORMC/CRMC has an interest in protecting its confidential and proprietary information and in making sure that its employees do not violate criminal or civil law, including HIPAA, by revealing confidential, identifying, or personal information about any individual associated with ORMC/CRMC.

DEFINITIONS: Greater Hudson Valley Health System (now known as Garnet Health) — is comprised of the corporate entities Orange Regional Medical Center (ORMC) and Catskill Regional Medical Center (CRMC). For the purposes of this policy GHVHS also includes, but is not limited to, the physical facilities, web content, policies, practices, procedures, management, employees, contractors, vendors, suppliers, business partners, board members, patients, residents, volunteers, students, interns, customers and/or other individuals and organizations affiliated with, conducting business with, or having a business interest in ORMC or CRMC. Social networking – includes all types of posting on the Internet or other electronic media, including, but not limited to, social networking sites (i.e. Facebook, MySpace, or Linkedln); blogs and other on-line journals and diaries; bulletin boards and chat rooms; microblogging (i.e. Twitter); text messaging; and the posting of audio/video content on YouTube and other similar media sites.

PROCEDURE: to protect ORMC’s/CRMC’s identity, integrity and reputation, and to reduce the likelihood that employee participation and posts on social networking sites might have an adverse effect on the ORMC/CRMC, employees must adhere to the following:

· Employees may not post on a blog or social networking site during their working time or at any time using ORMC/CRMC equipment or property.

· Always be fair and courteous to fellow associates, customers, members, suppliers or people who work on behalf of ORMC/CRMC. Also, keep in mind that you are more likely to resolve work-related complaints by speaking directly with your co-workers or by utilizing our reporting policies than by posting complaints to a social media outlet. Nevertheless, if you decide to post complaints or criticism, avoid using statements, photographs, video or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage customers, members, associates or suppliers, or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of race, sex, disability, religion or any other status protected by law or company policy.

· Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts you have altered. Remember that the Internet archives almost everything; therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false about ORMC/CRMC, fellow employees, patients, suppliers, people working on behalf of ORMC/CRMC.

· Do not create a link from your blog, website or other social networking site to a Greater Hudson Valley Health System website without identifying yourself as a ORMC/CRMC employee.

· Express only your personal opinions. Never represent yourself as a spokesperson for ORMC/CRMC. If ORMC/CRMC is a subject of the content you are creating, be clear and open about the fact that you are an employee and make it clear that your views do not represent those of ORMC/CRMC, fellow employees, patients, suppliers or people working on behalf of ORMC/CRMC. If you do publish a blog or post online related to the work you do or subjects associated with ORMC/CRMC, make it clear that you are not speaking on behalf of ORMC/CRMC. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of the Greater Hudson Valley Health System. They have not been reviewed or approved by the Greater Hudson Valley Health System”

· All ORMC/CRMC rules and policies regarding confidential and proprietary business information apply in full to blogs and social networking sites. Specifically, this includes, but is not limited to: competitive information; business plans; patient information (especially information protected by HIPAA); and any other information that is not for disclosure outside of ORMC/CRMC.

· Related ORMC/CRMC internet, computer use and conduct policies apply to visits to, and postings on, social networking sites including, but not limited to those dealing with: harassment; sexual harassment; non-discrimination; ethics; standards of conduct; use of the internet; and use of voice mail, e-mail and computer systems. A list of applicable policies appear in Attachment A. Note that this list is not necessarily all inclusive and other policies may be deemed applicable based on their relevance.

· ORMC/CRMC’s policies prohibiting discrimination, retaliation, and/or harassment based on age, marital status, partnership status, citizenship, color, race, national origin, creed, religion, sex, sexual orientation, gender identity, genetics, disability, union membership, veteran status or any other protected characteristic as established by law as well as ORMC’s/CRMC’s Workplace Violence policies apply equally to employee comments concerning ORMC/CRMC and its affiliates on social networking sites, even if done on non working time. Employees are encouraged to review those policies and sections of the Employee Handbook for further guidance.

· Requests for employment references or recommendations, received through social networking, should be referred to Human Resources and must not be responded to via social networks.

ORMC/CRMC reserves the right to monitor public blogs and social networking forums for the purpose of protecting its interests and maintaining compliance with this policy. Violations of this policy should be brought immediately to the attention of the Vice President of Human Resources or her/his designee.

Any employee who violates this policy may be subject to disciplinary action, up to and including termination

1. This policy is not intended to restrict an employee’s right to discuss wages and working conditions with co-workers, engage in protected union and concerted activities, or in any other manner limit employees’ rights under the National Labor Relations Act.

2. Social network postings may be made by individuals authorized by ORMC/CRMC to post such content within the scope of their job, which are made solely for the benefit of ORMC/CRMC.