Social Media Policy
Participation in social media has become a popular communication vehicle between Magellan’s colleagues and customers, the general public, traditional and non-traditional media, and other community stakeholders. Such participation may include, but is not limited to, postings in online forums, blogs, wikis, Facebook, LinkedIn, MySpace, YouTube, Twitter, media sites or similar types of online forums. The purpose of this policy is to ensure that communications related to Magellan in social media are consistent with Magellan's Employee Handbook, Code of Conduct, policies and procedures, and applicable laws, including laws concerning privacy, confidentiality, copyright and trademarks. Additionally, we must ensure that Magellan-sponsored social media are used in an appropriate manner and communications must be accurate and expressed in a respectful, professional manner.
Magellan respects the rights of employees to appropriately express their views and opinions, including through the use of social media. In order to protect employees and Magellan, when participating in Magellan-sponsored social media or in other social media where the communication is or could be Magellan related, you should abide by the following guidelines:
- Be responsible. Communications made in social media should be consistent with Magellan’s Employee Handbook, Code of Conduct, values, policies and applicable laws. Employees are personally responsible for their own communications and can be held liable if any party (including, but not limited to, Magellan) deems an employee’s communication to be improper, illegal, in violation of this policy, libelous, harassing, threatening, defamatory, or disclosing confidential information.
- Maintain confidentiality. Communications in social media should never contain information that discloses a member’s Protected Health Information (PHI) or Personally Identifiable Information (PII) in any way, including photographs or video. Even if an individual is not identified by name within the information you wish to use or disclose, if there is a reasonable basis to believe that the person could still be identified from that information, then its use or disclosure could constitute a violation of law and/or regulations including without limitation the Health Insurance Portability and Accountability Act (HIPAA), and Magellan’s privacy policies. If you have any question whether information is PHI or is sufficiently de-identified, contact the HIPAA Privacy Officer before posting the information.
- Protect yourself and our business. Communications made through social media must not contain any Magellan Information that is confidential, proprietary or a trade-secret. Also, use only approved social media channels — and not personal social media sites or pages — to conduct Magellan business. Do not disclose or discuss material Company information, matters, or developments unless this information has been previously disclosed to the public. In addition, do not comment on legal matters or ongoing crises or post any information which would result (or have the potential to result) in a detriment to Magellan’s business, including, but not limited to, the Magellan’s reputation and goodwill. If you are unsure if information is publically available or is otherwise inappropriate to post, contact Corporate Communications or the Investor Relations Department before posting any such information.
- Respect copyrights. Individuals should not use copyrighted materials (written, audio, video and all other electronic forms) in their social media communications without proper permission. Company and/or product logos may not be used without written permission, as they imply that you may be speaking on behalf of Magellan. In addition, you may not use Magellan’s name for personal benefit and your online activity should not present a conflict of interest. Do not use photographs or video of Magellan’s premises, processes, operations, or services without Magellan’s prior written approval.
- Be respectful of others. Individuals should refrain, at all times, from using language that is obscene, defamatory, derogatory, profane, libelous, threatening, harassing, discriminatory, abusive, hateful, discriminatory or humiliating to another person or entity. Speak respectfully of Magellan, its employees, customers and members, as well as other members of Magellan’s industry including its competitors. Respect the privacy of Magellan employees and contractors by obtaining permission before discussing or sharing information about or images of colleagues and/or internal workplace events or disclosing colleagues’ personal contact information. Remember, you are “speaking” publicly and your contribution may stay searchable and retrievable for a long time to a broad audience - both internally and externally. In addition, Managers should not send “friend” requests to subordinates unless there is a valid business purpose for doing so. Any employee may reject a friend request from any other employee without fear of retaliation.
- Be honest and accurate. When an employee, temporary staff member, contractor, volunteer or other associate of Magellan communicates in social media about Magellan, provide full disclosure acknowledging the relationship with Magellan and include a disclaimer advising that you are not speaking officially on behalf of the organization. For example, add a disclaimer to read: “The opinions and positions expressed are my own and don’t necessarily reflect those of Magellan Health, Inc.” Never misrepresent yourself or information about Magellan. Never speak out on behalf of Magellan or hold yourself out as speaking out on behalf of Magellan unless you have been authorized by the Company to do so. Also, communicate accurately and correct errors or omissions in a timely fashion (rather than deleting them).
- Know who to call.If you are approached by the media concerning anything that you or another Magellan employee may have posted/said in social media concerning Magellan, contact the Corporate Communications department at CorporateCommunications@Magellanhealth.com.
Magellan provides employees with E-mail and Internet access to support Magellan business purposes only. Although users who are given access to these tools may make incidental personal use of them, they may not make extensive personal use of them either during work or non-work time. Each user’s manager has the right and responsibility to determine what “extensive use” is and should refer to the Communications and System Security policy in the Employee Handbook for further information and guidance.
Individuals who have concerns regarding workplace conduct or inappropriate behavior are encouraged to contact their immediate supervisor, Human Resources or the Compliance Hotline by sending an e-mail to Compliance@magellanhealth.com. Social media is not the most effective or appropriate way to resolve such issues, and may only serve to make matters worse. This Policy will not be construed or applied in a manner that improperly interferes with employees’ rights under the National Labor Relations Act.
Glossary of Helpful Terms:
- Blog - Short for “Web log”, a site that allows an individual or group of individuals to share a running log of events and personal insights with online audiences.
- Magellan Information - Information in any form or media that is created by or on behalf of Magellan in the course and scope of its business, regardless of whether that information is maintained or stored by Magellan and others on Magellan’s behalf. Examples of Magellan information include, but are not limited to, patient and member records, personnel records, financial information, Company competitive information, customer and employee names, Magellan-developed intellectual property, and business e-mail messages.
- Protected Health Information (PHI) or Personally Identifiable Information (PII) - Any individually identifiable information (oral, written or electronic) regarding a member/patient of Magellan collected, received, created, transmitted or maintained in connection with his/her status as a member or patient. PHI/PII includes, but is not limited to, information about a member/patient’s physical or mental health, the receipt of health care, or payment for that care; member/patient records, enrollment and disenrollment information; name, address, Social Security Number, account number, security code, information from or about transactions, driver’s license number, financial or credit account numbers, phone numbers, or other personal identifiers.
- Podcast - A collection of digital media files distributed over the Internet, often using syndication feeds for playback on portable media players and personal computers.
- RSS feeds or Syndication feeds - A family of different formats used to publish updated content such as blog entries, news headlines or podcasts that “feed” this information to subscribers via e-mail or by an RSS reader.
- Social media - Includes, but are not limited to, Blogs, Podcasts, discussion forums, chat rooms, on-line collaborative information and publishing systems that are accessible to internal and external audiences (i.e. Wikis), RSS feeds, Syndication feeds, video sharing, and social networks such as Facebook, MySpace, Twitter, YouTube and LinkedIn.
- Wiki - Allows users to create, edit and link Web pages easily. Often used to create collaborative Web sites (called “Wikis”) and to power community Web sites.