Policy for Government's Presence in Social Media - Recommendations

1. Data Retention

The Government's communication to citizens via social media should follow the same data retention policy as its communication through other electronic and non-electronic channels.

Data portability compliance varies from one social media platform to another. Hence, privileged access may be mandated by the Government along the same lines “take down notices” and “information requests” currently being sent to social media and other platforms for intellectual property rights infringement and other offences.

2. Privacy

Yochai Benkler has famously stated that privacy is the protection of the weak from scrutiny by the powerful while transparency is the exposure of the powerful to scrutiny by the weak.¹

It is critical that social media policy for the Government is compliant with existing law governing data protection and privacy.² As Benkler said, privacy protection should be a function of power – ordinary citizens should be afforded greater protection than Government personnel. Each department of the Government may be recommended to publish their own set of additional protections to safeguard privacy of citizens while maintaining highest levels of transparency of Government bodies.

3. Certifying Official Accounts

Some social media platforms have the ability to certify or validate an official account. Such validation must be made mandatory for all Government presence across various social media platforms. The mere existence of official Government social media accounts does not mean that the Government officers cannot use their own personal unofficial social media accounts. However, there must be a very clear and discernable distinction between a Government officer's personal (individual) social media presence and the official social media presence of a Government department or Ministry.

While individual officers are encouraged to set up their own personal social media presences, the official accounts must be in the format: Ministry/Department (Acronym) along with Designation (Acronym) of the official, so that the fans/followers/friends accumulated during the tenure of a particular official can be handed over to the next person who takes the same office. In order that this process of handing over is smooth and uniform across various Government departments, it is recommended that the protocol for handing over of social media presences be clearly laid down and communicated to all the Government departments.

4. Social Media Integration with Government Portals

Social media must be integrated with the official websites. Ideally, the websites should use Free and Open Source Software (FOSS) content management system with full compliance with web accessibility guidelines such as W3C's Web Content Accessibility Guidelines (WCAG) so that the RSS feeds of newly added content can be broadcast via multiple social media presences. Therefore, social media is seen as an additional benefit accruing from already existing efforts and investments of the Governments in electronic publishing.

In fact, it would be greatly beneficial for citizens if a constitutent relationship management software with tracking number is used for all social media and email communication by the Government. This will bring about a higher level of transparency and accountability on part of the Government.

5. Security

Social media presences will be the target of malicious elements online. Government social media presences are, in fact, at a greater risk of being subject to such attacks. Therefore, Government security standards must be adhered to including change of passwords regularly for Government social media accounts.

6. Mass Outreach

In order to neutralise the pro-elite bias of social media, a special outreach to non-elites via mobile phones must be an integral part of the Government's social media strategy. Digitally enabled middle class activism can undermine true participatory democracy and this must be resisted.

7. Rude Accountability

Occasionally, citizens may resort to the use of inflammatory language and tone with Government authorities to claim public services and to sanction service failures. Such communications referred to as 'rude accountability' accompanied by trolling are common phenomena which the Government can expect around its social media presences. It is recommended that these incidents be ignored at the first instances instead of penalising them. The Department of Information Technology (DIT) should prescribe protocol for escalation in case of systemic trollers. It is to be noted that the lower threshold for freedom of speech as prescribed by the Information Technology Act and Information Technology Rules should not serve as the yardstick on Government social media presences for characterising citizens' behaviour as offences. It is important that the Government allows a greater space for citizens to communicate with the Government and exercise their freedom of expression.

8. Managing Expectations

Each Government Ministry/Department/Official should publicly manage expectations for their social media presences in the form of an explicit, published “social media” policy in which expectations surrounding integral aspects of communication with the public such as public comments, speed of response and procedure for escalation are clearly documented. This will ensure that citizens have fewer undue expectations from the social media presence of a particular Government authority.

9. Brevity of Communications

Social media particularly, micro blogging and SMS is based on brevity of communications. Therefore, when a social media presence is branded or named, it must be ensured that the name takes up least number of characters so that it enables viral propagation.

In order to standardise on the spellings employed for SMS slang common in micro blogging and SMSes, it is recommended that Government officials use modern clients with in-built support for such functionality to avoid being embarrassed online.

10. Official Logo

The official logo of the Government Ministry/Department should be an integral part of Government social media presences. The logo may also be published where applicable so that it could be the Public key. A link to the official website should be employed wherever appropriate in order to establish credibility of the social media presence.

11. Proactive Information Disclosure

Social media should be used as a means to uphold RTI obligations for proactive information disclosure and to drive traffic to the website which should ideally be an archive of such comprehensive proactive disclosures.

12. Alternative Open Platforms

Wherever free and open/ non-proprietary/ community-owned social media infrastructure exists, the Government will be obliged to use the alternative social media platform in addition to mainstream platforms. For instance, for every Government authority's presence on Twitter, the Government is obliged to ensure that such authority also has a presence on status.net.

13. Uniformity of Communication

Social media can only be used by the Government to communicate existing Government information and propagate official policy terms to the public. Great care must be taken to avoid propagation of unverified facts and frivolous misleading rumours which tend to circulate often through miscreants on social media platforms. It is recommended that any information published by the Government on a social media platform should be published only when such information can also be published through other existing Government channels.

If the Government has to be a good neighbour in social media, it should also contribute to viral dissemination of relevant public information by way of re-tweeting, commenting and liking. Considering that the Government might lend its credibility to dubious causes through such endorsement, a protocol should be in place as part of social media policy for the Government to ensure that baseless and dubious claims are not vouched for by the Government.

1See Yochai Benkler, “A Free Irresponsible Press: Wikileaks and the Battle over the Soul of the Networked Fourth Estate” (2011), forthcoming Harvard Civil Rights – Civil Liberties Law Review available at http://bit.ly/e84QhK.