Managing the Legal Risks of Social Media Daniel Goldman Legal counsel Mayo Clinic

Managing the Legal Risks of Managing the Legal Risks of Social MediaSocial Media

Daniel GoldmanDaniel Goldman

Legal counselLegal counsel

Mayo ClinicMayo Clinic

What is “Social Media”?What is “Social Media”?

• ““social” websites in which users social” websites in which users interact with the site and each otherinteract with the site and each other

• interconnected networks of friends interconnected networks of friends or followersor followers

The Power of Social MediaThe Power of Social Media

The Social Media RevolutionThe Social Media Revolution

Major Social Media SitesMajor Social Media Sites

• FacebookFacebook•King of the hill: 500 million active users. 250 King of the hill: 500 million active users. 250 million logon each daymillion logon each day

Major Social Media SitesMajor Social Media Sites• MySpaceMySpace

•Started the revolution; now a historical artifactStarted the revolution; now a historical artifact•Younger demographicYounger demographic•Shifted focus to music and entertainmentShifted focus to music and entertainment•200 million users200 million users•May be in death spiral: 1/11 laid off 50% of work forceMay be in death spiral: 1/11 laid off 50% of work force

Major Social Media SitesMajor Social Media Sites• Twitter Twitter

• Broadcast texting to “followers”: Broadcast texting to “followers”: • 140 character “tweets”140 character “tweets”• Can include links Can include links

• Subscription modelSubscription model• ““Follow” people to get their tweetsFollow” people to get their tweets• People who follow you get your tweetsPeople who follow you get your tweets

• Claims 175M active usersClaims 175M active users

• 1B tweets sent weekly1B tweets sent weekly

TwitterTwitter

• Become a business toolBecome a business tool• Channel for sharing professional Channel for sharing professional

news/informationnews/information• HIPAA breach notification rulesHIPAA breach notification rules• Red flag rule postponement.Red flag rule postponement.• New Massachusetts privacy revisionsNew Massachusetts privacy revisions

• Huge marketing reachHuge marketing reach• Quick, nimble, dynamicQuick, nimble, dynamic• Able to quickly interact with massive Able to quickly interact with massive

numbers of customers/potential numbers of customers/potential customerscustomers

TwitterTwitter

Twitter: Companies Engaging With Twitter: Companies Engaging With their Customerstheir Customers

TwitterTwitter


• Linked InLinked In•Professional Networking SiteProfessional Networking Site•Can post status updates and send Can post status updates and send messagesmessages


• YouTubeYouTube•Video sharing siteVideo sharing site•300 million visitors per month300 million visitors per month


• YammerYammer•““private” social network for companiesprivate” social network for companies•Used by 90,000 companies; 80% of F500Used by 90,000 companies; 80% of F500


• Location-based social media sitesLocation-based social media sites• FoursquareFoursquare• Check in at various locations to let others Check in at various locations to let others

know where you areknow where you are• Become “Mayor of a location”Become “Mayor of a location”• Earn rewards/discounts from retailers based Earn rewards/discounts from retailers based

on number of check inson number of check ins• Leave reviews/comments on Leave reviews/comments on

locations/retailerslocations/retailers• 200k users 12/09 5M users 10/10200k users 12/09 5M users 10/10

• Major sites adding location/check-in featuresMajor sites adding location/check-in features• Facebook PlacesFacebook Places• 30M users have tried30M users have tried

Location-Based Social Media: Location-Based Social Media: FoursquareFoursquare

FoursquareFoursquare




Who’s Using Social Media:Who’s Using Social Media:IndividualsIndividuals

• Recent Harris poll (1/11)Recent Harris poll (1/11)• 65% of Americans report 65% of Americans report

themselves a social media usersthemselves a social media users• Up from 35% in 2008Up from 35% in 2008• Older users rise dramaticallyOlder users rise dramatically• Baby boomers (46-64) 9%-43%Baby boomers (46-64) 9%-43%• Mature (65+) 4%-16%Mature (65+) 4%-16%

Who’s Using Social Media: Who’s Using Social Media: BusinessesBusinesses

• 80% of Fortune Global 100 80% of Fortune Global 100 companies use some form of social companies use some form of social media (blogs, twitter, facebook)media (blogs, twitter, facebook)

• Most used:Most used:• Twitter: 60%Twitter: 60%• Facebook: 54%Facebook: 54%• YouTube: 50%YouTube: 50%

Source: Burson-Marsteller Fortune Source: Burson-Marsteller Fortune Global100 Social Media Study 2/2010Global100 Social Media Study 2/2010

Social Media Adoption in Social Media Adoption in HealthcareHealthcare

• 906 US hospitals using social media 906 US hospitals using social media (approx 15%)(approx 15%)• 719 Facebook pages 719 Facebook pages • 674 Twitter Accounts 674 Twitter Accounts • 439 YouTube Channels 439 YouTube Channels • 439 LinkedIn Accounts 439 LinkedIn Accounts • 106 Blogs 106 Blogs

Source: www.edbenett.orgSource: www.edbenett.org

Most Popular Twitter feedsMost Popular Twitter feeds

• Mayo Clinic (MN/AZ/FL): Mayo Clinic (MN/AZ/FL): • 97,000 followers97,000 followers

• St. Jude Children’s (TN)St. Jude Children’s (TN)• 11,000 followers11,000 followers

• Children’s Nat’l Med Ctr (DC)Children’s Nat’l Med Ctr (DC)• 8,600 followers8,600 followers

• Emory John’s Creek Hosp (GA)Emory John’s Creek Hosp (GA)• 8,300 followers8,300 followers

• Aurora St. Luke’s (WI)Aurora St. Luke’s (WI)• 8,3008,300

Most popular Facebook PagesMost popular Facebook Pages

• St. Jude’s (TN)St. Jude’s (TN)• 338,000 fans338,000 fans

• Children’s Hospital of Boston (MA)Children’s Hospital of Boston (MA)• 475,000 fans475,000 fans

• Arkansas Children’s Hosp (AR)Arkansas Children’s Hosp (AR)• 76,000 fans76,000 fans

• Mayo Clinic (MN/AZ/FL)Mayo Clinic (MN/AZ/FL)• 35,000 fans35,000 fans

• VHA (DC)VHA (DC)• 30,000 fans30,000 fans

Common Uses of Social Media in Common Uses of Social Media in HealthcareHealthcare

• Deliver informationDeliver information• health and wellnesshealth and wellness• Your hospital/brandYour hospital/brand

• Connect and interact with patients, Connect and interact with patients, potential patients and “friends” of your potential patients and “friends” of your brandbrand

• Foster online communities Foster online communities • Patients and individuals can interact Patients and individuals can interact

with each other re health and your with each other re health and your brandbrand

Benefits of Business Use of Social Benefits of Business Use of Social MediaMedia

• Interactive nature: Dialogue not Interactive nature: Dialogue not monologuemonologue• More meaningful interactionsMore meaningful interactions• Chance to listen as well as speak to Chance to listen as well as speak to

your customers: free market researchyour customers: free market research

• More trusted than advertisingMore trusted than advertising

• CommunityCommunity• Particularly powerful with health issuesParticularly powerful with health issues• Esp significant/chronic health Esp significant/chronic health

conditions (e.g. depression)conditions (e.g. depression)

Benefits of Business Use of Benefits of Business Use of Social MediaSocial Media

• It’s where the people are, esp. under 30It’s where the people are, esp. under 30• Can interact with/influence large Can interact with/influence large

numbers of peoplenumbers of people

• It’s freeIt’s free

• Did I mention that it’s free?Did I mention that it’s free?

Why is Mayo Clinic Involved in Why is Mayo Clinic Involved in Social MediaSocial Media

• Build our brandBuild our brand• How our brand has grown for last How our brand has grown for last

100 years100 years• Hi-Tech WOMHi-Tech WOM

• Powerful tool to deliver health Powerful tool to deliver health informationinformation

• Power and immediacy of communityPower and immediacy of community

Benefits of Using Social Media in Benefits of Using Social Media in HealthcareHealthcare

• ““Social media gives me access to a world of people living Social media gives me access to a world of people living with type 1 diabetes, just like me. Any hour of the day or with type 1 diabetes, just like me. Any hour of the day or night I can tune in to discussions on Twitter or Facebook, I night I can tune in to discussions on Twitter or Facebook, I can read thousands of blog posts written by people from all can read thousands of blog posts written by people from all walks of life, all living with type 1 diabetes, and I can find walks of life, all living with type 1 diabetes, and I can find YouTube videos that make me laugh and cry. I can find YouTube videos that make me laugh and cry. I can find connections. I can find people who understand exactly what connections. I can find people who understand exactly what I’m going through. These people and their stories become I’m going through. These people and their stories become an emotional lifeline. Suddenly I don’t feel so alone or an emotional lifeline. Suddenly I don’t feel so alone or isolated. In fact I often feel inspired and empowered by what isolated. In fact I often feel inspired and empowered by what I’ve seen.”I’ve seen.”

• Scott Johnson Scott Johnson http://www.diabetesdaily.com/johnson/http://www.diabetesdaily.com/johnson/

Mayo Clinic: Mayo Clinic: Facebook, Twitter, Youtube, BlogFacebook, Twitter, Youtube, Blog

Changing Health CommunicationChanging Health Communication

• Mayo Clinic Center for Social Mayo Clinic Center for Social MediaMedia•Create resources for use at Create resources for use at Mayo Clinic that can be Mayo Clinic that can be shared with organizations shared with organizations wanting to use social media wanting to use social media in health and health carein health and health care

• Social Media Health Network Social Media Health Network •Membership group for Membership group for orgs wanting to use social orgs wanting to use social media to improve media to improve healthcarehealthcare•Sharing, Collaboration Sharing, Collaboration development of resourcesdevelopment of resources

Challenges of Social MediaChallenges of Social Media

• SpeedSpeed• Interconnected nature of social Interconnected nature of social

networks means information networks means information moves quicklymoves quickly• Less time to analyze and react Less time to analyze and react

than traditional mediathan traditional media

Challenges of Social MediaChallenges of Social Media• Reach Reach •Social media gives individuals access to Social media gives individuals access to staggering numbers of peoplestaggering numbers of people

Challenges of Social MediaChallenges of Social Media• Reach Reach • ““United Breaks Guitars" video on United Breaks Guitars" video on

YouTube: 10 million viewsYouTube: 10 million views


• Blurring of professional/personal lives Blurring of professional/personal lives • Most social media sites encourage sharing of Most social media sites encourage sharing of

info about professional livesinfo about professional lives• Difficult to separate what happens at work from Difficult to separate what happens at work from

other events in your lifeother events in your life• Difficult to not reveal where you workDifficult to not reveal where you work• Many challenges when lawful personal conduct Many challenges when lawful personal conduct

is in tension with professional expectationsis in tension with professional expectations• Particular challenge in professions such as Particular challenge in professions such as

healthcare/legal with high ethical expectations healthcare/legal with high ethical expectations


• Generation of “lifecasters”Generation of “lifecasters”• Expectation of sharing of all Expectation of sharing of all

details of lifedetails of life• Including what happens at workIncluding what happens at work• Not the same expectation of Not the same expectation of

privacy as older generationprivacy as older generation• In tension with increasingly strict In tension with increasingly strict

privacy lawsprivacy laws

Challenges Unique to Specific Challenges Unique to Specific IndustriesIndustries

• PrivacyPrivacy• HIPAA, GLBA and state privacy laws make HIPAA, GLBA and state privacy laws make

information sharing a challenge in privacy-information sharing a challenge in privacy-regulated industries such as healthcare, regulated industries such as healthcare, financial services, legal.financial services, legal.

• Stakes are high if employees act Stakes are high if employees act inappropriatelyinappropriately• Fines, lawsuitsFines, lawsuits• PR and Brand risksPR and Brand risks

• Can limit your ability to respond to critics and Can limit your ability to respond to critics and unhappy customersunhappy customers

Ethical Issues: “Friending” ClientsEthical Issues: “Friending” Clients

• Raises challenging issues regarding Raises challenging issues regarding appropriate boundaries for appropriate boundaries for professional relationshipsprofessional relationships• Blurs what is and isn’t part of the professional Blurs what is and isn’t part of the professional

relationshiprelationship• Particular issue with respect to lawyers Particular issue with respect to lawyers

friending judges and other litigants/clients, friending judges and other litigants/clients, physicians friending patientsphysicians friending patients

• Professions are just beginning to sort out the Professions are just beginning to sort out the ethical issuesethical issues

Managing Risk Through Social Managing Risk Through Social Media Policies: General ThoughtsMedia Policies: General Thoughts

• No “one size fits all” approach.No “one size fits all” approach.• Policy is as much a reflection of Policy is as much a reflection of

corporate culture as lawcorporate culture as law• Must understand your company’s Must understand your company’s

brand, tolerance for dissent and brand, tolerance for dissent and risk, relationship with workforce risk, relationship with workforce and balance that with what the law and balance that with what the law allowsallows

Social Media is a Dialogue, Not a Social Media is a Dialogue, Not a MonologueMonologue

• Traditional marketing/advertisingTraditional marketing/advertising• billboardbillboard• Pro: Advertiser controls messagePro: Advertiser controls message• Con: People no longer trust, no ability to hear Con: People no longer trust, no ability to hear

what customer wantswhat customer wants

• Social mediaSocial media• ConversationConversation• Pro: interactive, people trust, you can hear Pro: interactive, people trust, you can hear

what’s important to your customerwhat’s important to your customer• Con: much less control. “Community” Con: much less control. “Community”

expects you will respond to criticism, not expects you will respond to criticism, not “censor” it.“censor” it.


• Expectation is that people will talk back to Expectation is that people will talk back to you, you, and that you will listen.and that you will listen.

• Must have a thick skin to participate in Must have a thick skin to participate in social mediasocial media

• You may have to tolerate some things you You may have to tolerate some things you don’t likedon’t like• Esp challenging in Healthcare: HIPAA Esp challenging in Healthcare: HIPAA

limits your response to criticismlimits your response to criticism


• Even if you can respond, should you?Even if you can respond, should you?


• However: cannot really “opt out” of social However: cannot really “opt out” of social media. media. • You can choose not to participateYou can choose not to participate• HOWEVER, it doesn’t mean HOWEVER, it doesn’t mean

patients/customers competitors aren’t talking patients/customers competitors aren’t talking about you.about you.

• If you don’t participate, you’ve lost your If you don’t participate, you’ve lost your opportunity to participate in/shape the opportunity to participate in/shape the conversationconversation

Tolerating CriticismTolerating Criticism



Employee Education and Employee Education and Awareness are CriticalAwareness are Critical

• Make sure policies are accessible: on your Make sure policies are accessible: on your intranet/internetintranet/internet

• Make sure your employees receive trainingMake sure your employees receive training• Include examples, not always obvious Include examples, not always obvious

what’s a HIPAA violation or practice of what’s a HIPAA violation or practice of medicinemedicine

• The best policies are useless if employees The best policies are useless if employees aren’t aware of them, don’t understand aren’t aware of them, don’t understand themthem

Expect and Expect and Plan forPlan for Crises Crises

• Speed/Reach of social media mean Speed/Reach of social media mean crisis will happen with extraordinary crisis will happen with extraordinary speedspeed

• Little time to react/difficult to reign inLittle time to react/difficult to reign in

Expect and Expect and plan forplan for crises crises

• Domino’s pizza: YouTube video showing Domino’s pizza: YouTube video showing employees tainting foodemployees tainting food•1 million views in 2 days1 million views in 2 days

• Identify a crisis team and a crisis plan Identify a crisis team and a crisis plan beforebefore a crisis happens a crisis happens

Plagiarize!Plagiarize!

• Build off the work of othersBuild off the work of others

• Many people thinking about this Many people thinking about this issue: many good approachesissue: many good approaches

• List of policies in written materialsList of policies in written materials

Drafting Social Medial PolicesDrafting Social Medial PolicesIssues to Address in Your PolicyIssues to Address in Your Policy

• Use of social media during work timeUse of social media during work time• Most companies will prohibitMost companies will prohibit• Some will encourageSome will encourage• Can often be addressed by Can often be addressed by

existing policiesexisting policies• Can you enforce an outright ban Can you enforce an outright ban

with mobile devices?with mobile devices?

Stress Importance of Preserving Stress Importance of Preserving Customer PrivacyCustomer Privacy

• Critically important, esp in privacy regulated Critically important, esp in privacy regulated industries (e.g. healthcare, financial services). industries (e.g. healthcare, financial services). Legal and brand/pr riskLegal and brand/pr risk

• Lifecasting mentality+ speed + ease of posting Lifecasting mentality+ speed + ease of posting =danger=danger

• numerous instances of healthcare employees numerous instances of healthcare employees breaching privacy via social media (see written breaching privacy via social media (see written materials)materials)• Not always intuitive how privacy applies onlineNot always intuitive how privacy applies online• Lack of name not always enough to de-identify, esp in Lack of name not always enough to de-identify, esp in

smaller communitysmaller community• E.g. HIPAA applies to patients who are real-life friendsE.g. HIPAA applies to patients who are real-life friends• Incorporate examples into your educationIncorporate examples into your education

Stress Importance of Stress Importance of Professionalism Towards Professionalism Towards

CustomersCustomers

• Appropriate professionalism may be as Appropriate professionalism may be as important as legal privacy restraintsimportant as legal privacy restraints• Employees complaining about Employees complaining about

customers, even if de-identified can customers, even if de-identified can raise brand issuesraise brand issues

Identify Who Can Speak on Behalf Identify Who Can Speak on Behalf of the Companyof the Company

• Let employees know who can officially Let employees know who can officially speak on behalf of your Companyspeak on behalf of your Company

• Usually only designated PR Usually only designated PR employeesemployees

• Others must refrain from making it Others must refrain from making it appear that they are appear that they are

• Consider requiring disclaimers:Consider requiring disclaimers:• ““These are my personal views”These are my personal views”

Address the “Blurring” IssueAddress the “Blurring” Issue

• Two choices for employees:Two choices for employees:• If engaging in behavior If engaging in behavior

incompatible w brand/profession incompatible w brand/profession no identification with employerno identification with employer• If identify themselves as If identify themselves as

employees should not display employees should not display inappropriate behaviorinappropriate behavior


• Some cautions:Some cautions:• NLRB beginning to restrict employers in this NLRB beginning to restrict employers in this

areaarea• NLRA Section 8(a)(1): unfair labor practice NLRA Section 8(a)(1): unfair labor practice

for employers to interfere with or restrain for employers to interfere with or restrain collective activity of employeescollective activity of employees

• NLRB: talking publicly about working NLRB: talking publicly about working conditions, wages, workplace is protected conditions, wages, workplace is protected collective activitycollective activity


• American Medical Response of American Medical Response of Connecticut CaseConnecticut Case• NLRB files complaint over firing of employee NLRB files complaint over firing of employee

who criticized supervisor on Facebookwho criticized supervisor on Facebook• Employer’s policies:Employer’s policies:• Prohibited employees from posting pictures Prohibited employees from posting pictures

of themselves on the internet which depicts of themselves on the internet which depicts the company in any waythe company in any way

• Prohibits employees form making Prohibits employees form making “disparaging, discriminatory or defamatory “disparaging, discriminatory or defamatory comments when discussing the company or comments when discussing the company or the employee’s superiors, co-workers the employee’s superiors, co-workers and/or competitorsand/or competitors

American Medical Response CaseAmerican Medical Response Case

• From NLRB Complaint: From NLRB Complaint: • ““Respondent engaged in concerted Respondent engaged in concerted

activities with other employees by activities with other employees by criticizing Respondent’s supervisor criticizing Respondent’s supervisor on her Facebook page.”on her Facebook page.”


• ““This is a fairly straightforward case under This is a fairly straightforward case under the National Labor Relations Act — whether it the National Labor Relations Act — whether it takes place on Facebook or at the water takes place on Facebook or at the water cooler, it was employees talking jointly about cooler, it was employees talking jointly about working conditions, in this case about their working conditions, in this case about their supervisor, and they have a right to do that.” supervisor, and they have a right to do that.” NLRB Acting GCNLRB Acting GC


• Feb 2011: Case settled. Feb 2011: Case settled.

• Employer agrees to rewrite policies Employer agrees to rewrite policies to ensure it doesn’t restrict to ensure it doesn’t restrict employees from discussing wages, employees from discussing wages, hours and working conditionshours and working conditions

Student Transportation of America Student Transportation of America CaseCase

• Feb 2011NLRB files charge against STAFeb 2011NLRB files charge against STA• Social Media Policy was an unfair Social Media Policy was an unfair

labor practicelabor practice• Policy prohibits: Policy prohibits: the use of the use of

electronic communication and/or electronic communication and/or social media in a manner that may social media in a manner that may target, offend, disparage, or harm target, offend, disparage, or harm customers, passengers or customers, passengers or employees; or in a manner that employees; or in a manner that violates any company policyviolates any company policy


• Bottom Line:Bottom Line:• Stay up to date re NLRB decisionsStay up to date re NLRB decisions• Can’t prohibit employees from talking Can’t prohibit employees from talking

about terms and conditions of employment about terms and conditions of employment in a concerted matter (rule prohibiting in a concerted matter (rule prohibiting false statements re employer)false statements re employer)

• Can’t prohibit employees from talking to Can’t prohibit employees from talking to the media re ongoing labor disputes (rule the media re ongoing labor disputes (rule prohibiting all employee contact with prohibiting all employee contact with media)media)


• Some cautions:Some cautions:• some states prohibit employers some states prohibit employers

from regulating lawful off-duty from regulating lawful off-duty conductconduct• MN Stat 181.938 subd 2 (no MN Stat 181.938 subd 2 (no

termination for consumption of termination for consumption of lawful consumable productslawful consumable products

Stress the Preservation of Stress the Preservation of Business ConfidentialityBusiness Confidentiality

• Employees should be reminded that Employees should be reminded that they should not be discussing trade they should not be discussing trade secrets and business confidential secrets and business confidential business information onlinebusiness information online

• Use examples: Even posting that Use examples: Even posting that you’re attending a meeting with a you’re attending a meeting with a party you’re negotiating with can party you’re negotiating with can violate NDAviolate NDA

Prohibit Employees from Speaking Prohibit Employees from Speaking Anonymously or PseudonymouslyAnonymously or Pseudonymously

• Non-legal reason: considered Non-legal reason: considered dishonest and unethical in the social dishonest and unethical in the social media communitymedia community

• Legal reason: can violate the FTC Legal reason: can violate the FTC endorsement/testimonial guidelines if endorsement/testimonial guidelines if recommending your products or recommending your products or servicesservices

Address the FTC Address the FTC Endorsement/Testimonial Endorsement/Testimonial

GuidelinesGuidelines• Recently updated to specifically address Recently updated to specifically address

social mediasocial media

• Endorsers must disclose “material Endorsers must disclose “material connection” which includes:connection” which includes:• Free product to reviewFree product to review• Employment relationshipEmployment relationship• Enforcement action v Reverb Enforcement action v Reverb

CommunicationsCommunications• Pr firm employees post positive reviews of Pr firm employees post positive reviews of

clients’ apps on iTunes clients’ apps on iTunes • Deceptive b/c no discslosure of relationshipDeceptive b/c no discslosure of relationship

Address the FTC Address the FTC Endorsement/Testimonial Endorsement/Testimonial

GuidelinesGuidelines• Removes “results not typical” safe Removes “results not typical” safe

harbor. All claims must be harbor. All claims must be substantiatedsubstantiated

Restrictions on Lobbying/Political Restrictions on Lobbying/Political ActivityActivity

• For tax-exempts:For tax-exempts:

• IRS regs prohibit TE’s from IRS regs prohibit TE’s from supporting candidates in campaigns supporting candidates in campaigns and other types of political activityand other types of political activity

• Make sure those participating in Make sure those participating in social media on behalf of your TE social media on behalf of your TE company understand what is and company understand what is and isn’t permittedisn’t permitted

Prohibit Harassment of Other Prohibit Harassment of Other EmployeesEmployees

• Employees talk to and about each Employees talk to and about each other on social media’other on social media’

• Remind employees to follow Remind employees to follow applicable policies re mutual respect applicable policies re mutual respect and non-discrimination and and non-discrimination and harassment online.harassment online.

• Employer can be liable if aware of Employer can be liable if aware of this harassing behavior occurring this harassing behavior occurring online and does not take actiononline and does not take action

Respect Intellectual Property of Respect Intellectual Property of OthersOthers

• Make sure those using social media Make sure those using social media on your company’s behalf on your company’s behalf understand the rulesunderstand the rules• Especially copyright and fair useEspecially copyright and fair use• Misuse of materials of others can Misuse of materials of others can

lead to infringement claimslead to infringement claims

Explain the Rules Regarding False Explain the Rules Regarding False AdvertisingAdvertising

• Spell out what can and cannot be Spell out what can and cannot be said about your own company’s said about your own company’s products, as well as your products, as well as your competitor’s productscompetitor’s products

• This is another reason to be clear This is another reason to be clear about who can and cannot speak on about who can and cannot speak on behalf of your companybehalf of your company

Dangers of Not Having a Social Dangers of Not Having a Social Media PolicyMedia Policy

• ““Placenta Case”Placenta Case”•Nursing dismissed for Nursing dismissed for unprofessional conduct unprofessional conduct for posting to FBfor posting to FB•Court reinstates:Court reinstates:•““Photos are taken to be Photos are taken to be viewed, and if the students viewed, and if the students were given permission to were given permission to photograph the placenta, it photograph the placenta, it became irrelevant what they became irrelevant what they did with the pictures.”did with the pictures.”

•

More infoMore info

Twitter: Twitter: @danielg280@danielg280

Documents

Managing the Legal Risks of Social Media Daniel Goldman Legal counsel Mayo Clinic