Communications Policy

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HARLAXTON PARISH COUNCIL

POLICY DOCUMENT ON THE USE OF PERSONAL ELECTRONIC DEVICES, PC MOBILE PHONE, PC LAPTOP, COMMUNICATIONS AND SOCIAL MEDIA

Adopted on 10 January 2023


Introduction

The Council is continually looking at ways to improve its working and the use of electronic devices, electronic communications and social media is a major factor in delivering improvement

The use of digital and social media and electronic communication enables Harlaxton Parish Council to interact in a way which improves the communications both within the Council and between the Council and the people, businesses, and agencies it works with and serves.

The Council has a website and a Facebook account and uses email to communicate. The Council will always try to use the most effective channel for its communications and over time it may add to those channels of communication as it seeks to improve and expand the services it delivers. When these changes occur, this Policy will be updated to reflect the new arrangements.

As more information becomes available at the press of a button, it is vital that all information is treated sensitively and securely. Councillors are expected to maintain an awareness of  the confidentiality of information that they have access to and not to share confidential information with anyone. Failure to properly observe confidentiality may be seen as a breach of the Council’s Code of Conduct and will be dealt with through its prescribed procedures (at the extreme it may also involve a criminal investigation).

Internal communication and access to information within the Council. Internal communications between officers and members are just as important as those to the outside world. The Council is also subject to the Freedom of Information Act 2007 and therefore all communications of the Council can be subject to public scrutiny (with certain exemptions). Councillors are expected to abide by the Code of Conduct and the Data Protection Act in all their work on behalf of the Council.

As there are always ways in which to improve, this document must be seen as work in progress.

1.   Councillors Use of Personal Electronic Devices

Harlaxton Parish Council recognises the benefits of allowing Councillors to use their own electronic devices. Such devices include laptops, smart phones and tablets. The Parish Council is committed to supporting Councillors in this practice. The use of such devices to create and process Council information and data creates issues that need to be addressed, particularly around information security. The Parish Council must ensure that it remains in control of the data for which it is responsible, regardless of the ownership of the device used to carry out the processing. It must also protect its intellectual property as well as empowering Councillors to ensure that they protect their own personal information.

1.1.   Councillors who make use of their own devices must take responsibility for how they use them. They must:
 
•   Familiarise themselves with their device and its security features so that they can ensure the safety of Council information (as well as their own information)
•   Apply the relevant security features
•   Maintain the device themselves ensuring it is regularly patched and upgraded
•   The Parish Council cannot take responsibility for supporting devices it does not provide.

1.2.   Councillors using their own devices must take all reasonable steps to:

•   Prevent theft and loss of data
•   Keep information confidential where appropriate
•   Maintain the integrity of data and information
•   Take responsibility for any software they download onto their device

1.3.   Councillors must:

•   Set up passwords, passcodes, passkeys or biometric equivalents. These must be of sufficient length and complexity for the particular type of device
•   Where it is essential that information belonging to the Council is held on a personal device it should be deleted as soon as possible once it is no longer required. This includes information contained within emails
•   Ensure that relevant information is copied back onto Council’s systems and manage any
potential data integrity issues with existing information
•   Report the loss of any device containing Council data (including email) to the Clerk and Chair
•   Be aware of any Data Protection issues and ensure personal data is managed appropriately.
•   Report any security breach immediately to the Clerk and Chair
•   Ensure that no Council information is left on any personal device indefinitely. Particular care must be taken if a device is disposed of/sold/transferred to a third party
•   Ensure they immediately delete all council data from their personal devices once they have left the Council

1.4.   The Council will not routinely monitor personal devices. However, it does reserve the right to:

•   Prevent access to a particular device from either a wired or wireless network or both
•   Take all necessary and appropriate steps to retrieve information owned by the Council

1.5.   The Council must process ‘personal data’ i.e., data about identifiable living individuals in accordance with the Data Protection Act 2018 and the General Data Protection  Regulations. Sensitive personal data is information that relates to race/ethnic origin, political opinions, religious beliefs, trade union membership, health (mental or physical) or details of criminal offences. This category of information should be handled with a higher degree of protection at all times.

1.6.   The Council, in line with guidance from the Information Commissioner’s Office, recognises that there are inherent risks in using personal devices to hold personal data. Therefore, Councillors must follow the guidance in this document when considering using their own devices to process personal data.


2.   Parish Council Mobile Phone

2.1.   The Parish Council has a mobile phone which is solely to be used for Council related matters and is not – other than in an emergency – to be used to make or receive personal calls or text messages. No personal data should be stored in the handset or SIM card, other than an emergency contact number. It is primarily for use as a contact number for anyone wishing to leave a message for the Council.
 
2.2.   The Parish Council’s mobile number should be given only to Council related contacts, not
personal ones (other than an emergency contact).

2.3.   The mobile phone will normally be held by the Parish Clerk who is expected to monitor and deal with messages. Ideally, the phone will be checked for messages at least once a day Monday to Friday.  In the absence of the Parish Clerk a nominated Councillor  will be responsible for dealing with calls to this phone.

2.4.   Handheld mobile phones must not be used to make or receive calls while driving. This includes points when the vehicle is temporarily stationary. If caught by the police, a fixed penalty and potentially points on your licence may result.

2.5.   If it appears that the use of the Council’s phone to make outgoing calls is excessive or there appear to non-council related calls, the Council may investigate matters. If it appears that there has been wilful misuse of the phone disciplinary action may be considered.


3.   Parish Council Laptop

3.1.   The Parish Council has a laptop which is solely to be used for Council related matters.

3.2.   No unauthorised software packages or programs should be installed on the laptop.

3.3.   No personal data should be stored on this laptop.

3.4.   The Parish Clerk will normally hold the laptop. In the absence of a Parish Clerk a nominated Councillor will be responsible for the laptop.

3.5.   The laptop must be protected by a username and password. This password should not be shared with anyone other than an authorised member of Harlaxton Parish Council.

3.6.   The physical security of the laptop is the personal responsibility of the Parish Clerk or Councillor with responsibility for the laptop, regardless of where the laptop is being used.

3.7.   Virus protection is installed on the laptop. The Parish Clerk or responsible Councillor should ensure that the Virus Protection software is kept up to date and ensure that regular virus scans are carried out.

3.8.   All files on the laptop should also be stored on the G: drive of the HarlaxtonPC Gmail account.


4.   Communications

4.1.   Internal Communications

4.1.1.   Councillors are encouraged to have a separate email address for Council business.

4.1.2.   Councillors should also be careful only to copy (cc) essential recipients on emails. Note: Be careful with the use of the “Reply to All.” Only copy in those who need to know.

4.1.3.   Notwithstanding the above, Councillors should always endeavour to reply to the latest email in the thread to ensure that a single thread is maintained and to avoid divergent threads which may lose other comments.

4.1.4.   Emails marked Confidential must not be shared with anyone other than the sender and other recipients of that email.

4.1.5.   It is recognised that some councillors may choose not to use electronic media for communication. If this is the case the Clerk will ensure that hard copies are provided.

4.1.6.   Councillors and the Clerk may use WhatsApp/SMS as a convenient way to communicate at times. All are reminded that this policy also applies to such messages

4.1.7.   This policy is not designed to preclude private and or personal communications between councillors and/or officers in the daily running of the Council. Councillors are at liberty to communicate directly with other councillors in relation to their own personal views and, if appropriate, to copy their emails to the Clerk. Such procedures will ensure that a complete and proper record of all correspondence is kept.
 
4.1.8.   There should be no decision making by individuals involved where the Council is not convened. This goes against both the purpose of the Council and the requirement to be transparent to the public eye. It can also put Councillors at risk of personal liability. Councillors are entitled and encouraged to share views with each other, however, decision making shall be left to formal Council meetings, unless a clear mandate to proceed has been minuted. Where such a mandate exists, Councillors must be aware of, and abide by, the scope of the mandate to ensure they do not inadvertently or otherwise stray beyond it.

Note: Any emails copied the Harlaxton Parish Council email address become official and will be subject to The Freedom of Information Act

4.2.   External Communications

4.2.1.   The Parish Council email address is harlaxtonpc@gmail.com. The Council does not employ a full-time clerk but the email account is monitored regularly and emails will be responded to as quickly as possible. The aim is to respond to emails within 4 working days.

4.2.2.   All external communications on behalf of the Council will be sent from the harlaxtonpc@gmail.com email address by the Clerk or one of the nominated Councillors. Councillors should not use their own personal email or business addresses for external communications relating to Council business. Individual email addresses specifically for Council business may be used if this has been agreed with the Chair and Clerk.

4.2.3.   Councillors or committee members who have taken on responsibility for any action which involves written or verbal communication with third parties should lodge a copy of any communication with the Clerk. This is to ensure a consistent and complete set of records are held which reflect Council business and are available for reference should the need arise.

These shall include

▪   Letters or emails sent and received
▪   Notes or minutes of any meetings which may have been held or attended
▪   Notes or minutes of any face-to-face or telephone conversations held

4.2.4.   Councillors should not forward personal information to other people or groups outside of the Council, this includes names, addresses, email, IP addresses and cookie identifiers.

4.2.5.   This policy is not designed to preclude private and or personal communications between Councillors and/or officers in the daily running of the Council. Councillors are at liberty to communicate directly with other councillors in relation to their own personal views and, if appropriate, to copy their emails to the Clerk. Such procedures will ensure that a complete and proper record of all correspondence is kept.

4.3.   Parish Council Website

4.3.1.   The Council maintains a website. Where necessary, the Council may direct those contacting it to its website to see the required information, or it may forward their question to a member of the Council for consideration and response.
 
4.3.2.   Information shall be published on the website as and when required. The website should be reviewed at least once a month by the Clerk or nominated Councillor and kept as up to date as possible

4.3.3.   Information shall include:

•   Details of how to contact the Council
•   Councillor details
•   Date of the next Council meeting
•   Agendas of next meetings
•   Approved minutes of previous Council meetings
•   Annual reports
•   Annual returns
•   Policy Documents
•   Copies of the Village Voice newsletter
•   General Information about Harlaxton
•   Other useful community information

4.3.4.   The Council may, at its discretion, allow and enable approved local groups to have and maintain a presence on its website for the purpose of presenting information about the group’s activities.

4.4.   Social Media

4.4.1.   Harlaxton Parish Council has a Facebook account. The purpose of this is to provide information and updates regarding activities and opportunities within our Parish and to promote our community positively. It is not a substitute for the Parish Council Website, where information, agendas and minutes will remain. Links to documents on the website may be posted

4.4.2.   Communications from the Council will meet the following criteria:

•   Be civil, tasteful, and relevant
•   Not contain content that is knowingly unlawful, libellous, harassing, defamatory, abusive, threatening, harmful, obscene, profane, sexually oriented, or racially offensive
•   Not contain content knowingly copied from elsewhere and for which it does not own the copyright
•   Not contain any personal information
•   If it is related to official Council business, it will be moderated by either the Chair/Vice Chair of the Council with advice as necessary from the Clerk
•   Social media will not be used for the dissemination of any political advertising.

4.4.3.   In the main, all commenting, and messaging will be turned off. However, where commenting is left enabled, and to ensure that all discussions on the Council page are productive, respectful, and consistent with the Council’s aims and objectives, the Council asks members of the public to follow these guidelines:

•   Be considerate and respectful of others. Vulgarity, threats, or abuse of language will not be tolerated
•   Differing opinions and discussion of diverse ideas are encouraged, but personal attacks on anyone, including the Council members or staff, will not be permitted
•   Share freely and be generous with official Council posts but be aware of copyright laws. Be accurate and give credit where credit is due.
•   Stay on topic
•   Do not make comments of a commercial nature, nor advertise, market, or sell products.
•   The public are advised not include personal/private information in their social media posts.
•   Sending a message/post will not be considered as contacting the Council for official purposes. Correspondence should continue to be via letter to 3 Church Street, or email to harlaxtonpc@gmail.com.

4.4.4.   If any posts have comments enabled, the Parish Council retains the right to remove comments or content that includes:

•   Obscene or racist content.
•   Personal attacks, insults, or threatening language.
•   Potentially libellous statements.
•   Plagiarised material; any material in violation of any laws, including copyright.
•   Private, personal information published without consent.
•   Information or links unrelated to the content of the forum.
•   Commercial promotions or spam.
•   Alleges a breach of the Council’s policy or the law.