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New Charity Commission guidance: Charities and social media

Author: Kristina Kopic, Head of Charity and Voluntary Sector, ICAEW

Published: 12 Oct 2023

At the start of the year, the Charity Commission published its draft guidance for trustees on the use of social media by charities. The charity regulator has now published the consultation outcome and the updated new guidance, which helps trustees understand how their existing responsibilities and duties relate to the use of social media by the charity.

Why do trustees need to think about social media?

The Charity Commission had noticed in their case work, that some trustees had less oversight of how their charities used social media than they did in other aspects of the charity’s communication and engagement strategy. As a result, there was a concern that trustees may fail to grasp and manage the risks associated with the charity’s use of social media. The Commission’s guide encourages charity trustees to understand how their existing trustee duties relate to social media use by the charity and encourages charities to develop and implement a social media policy.

The guidance points out that social media can be a powerful and positive communication tool for charities, helping charities to connect with their stakeholders. However, it warns trustees to consider and manage the risks:

  • As a fast-paced tool, inappropriate content can be published quickly.
  • Once published, social media content can be difficult to undo.
  • The line between professional and personal lives can become blurred on social media.

I’m on a charity board – what should we do?

Trustees should refer to the Charity Commission guidance when they develop or review a social media policy for their charity. This will help them determine which internal controls are appropriate to manage the risks associated with the charity’s use of social media. Once developed, the policy should be kept under regular review to ensure it works effectively and remains relevant.

The core duties of charity trustees should be at the heart of their decisions on social media:

  • Does the charity’s use of social media further the charity’s purpose?
  • Is the use of social media in the best interests of the charity and compliant with laws?

Trustees also need to apply other regulation to the charity’s social media use, for example:

  • If social media is used for the charity’s campaigning and political activity, it needs to comply with the rules on political activity and campaigning
  • Trustees need to ensure processes are in place to keep people safe online, with particular care when dealing with vulnerable users. Read the “Operating online” section of the regulator’s guidance on safeguarding.

We want to develop a social media policy – where do I go for help?

The new Charity Commission guide includes a checklist for trustees and employees to use when they are developing (or reviewing) their social media policy. The level of detail required for the policy depends on the charity’s use of social media and the associated level of risk. Trustees are advised to involve those employees and volunteers who manage the charity’s social media channels in the development of the policy.

The policy should provide a framework for the charity’s use of social media, setting out how social media is used to deliver the charity’s purpose. It should also outline responsibilities: who is responsible for the day-to-day management of the charity’s social media and who needs to be involved if things go wrong. All staff and volunteers, including trustees, need to be familiar with the policy, including the charity’s guidelines on the use of personal social media accounts.

What about freedom of expression and privacy right of individuals?

Trustees, employees and charity volunteers have the right to exercise their freedom of expression within the law in their communications, both in their personal capacity and when communicating on behalf of the charity. Trustees are not expected to monitor personal social media accounts of employees or volunteers.

However, trustees should guide the charity’s staff and volunteers in their use of social media and make them aware of reputational risks, for example by implementing a social media policy.

How do I get started?

The guidance will help you consider different aspects:

  • Content posted or shared by your charity on social media.
  • Content posted or shared by trustees, employees or volunteers on their personal social media accounts.
  • Using social media to engage with the public.
  • Social media of organisations connected to your charity.
  • Engaging on emotive topics.
  • Campaigning or political activity on social media.
  • Fundraising on social media.
  • Online safety.

The guide also signposts training and resources to help trustees familiarise themselves with social media, and links to a Social media policy template (from CharityComms).

The Charity Commission’s guide ‘Charities and social media’ and its checklist are available here.