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SOCIAL MEDIA USE POLICY AND GUIDELINES DATE: 06/10/2025 PURPOSE/OVERVIEW This document outlines the Social Networking and Social Media Use Policy for the City of Muskegon (“the City”). In response to the fast-evolving landscape of digital communication and the increasing role of social media in how residents access information and engage with local government, this Policy establishes clear guidelines for the City’s presence and activity on social platforms. The purpose of this Social Media Use Policy and Guidelines (“the Policy”) is to define standards for the responsible and effective use of social media by City officials and employees. It ensures that all communications made on behalf of the City are authorized, professional, legally compliant, and aligned with public expectations. This includes adherence to relevant court rulings—such as Lindke v. Freed, 601 U.S. 187 (2024)—and compliance with applicable local, state, and federal regulations, including Michigan’s Freedom of Information Act (FOIA). SCOPE This Policy applies to all social media use by or on behalf of the City of Muskegon, including but not limited to staff, elected officials, appointed officials, committees, and departments. Employees of the Muskegon Police Department shall adhere to their department- specific social media policies. In areas where those policies do not address City specific issues, or for cross-departmental matters, this City policy shall apply. TYPES OF SOCIAL MEDIA USE PERSONAL PAGES All staff, elected officials, appointed officials and board and committee members may have personal social media sites. These sites shall remain personal in nature and be used to share personal opinions or non-work-related information. Following this principle helps ensure a distinction between sharing personal and City views. Personal pages shall not use City e-mail accounts or passwords in conjunction with a personal social media site. Campaign social media sites fall under this category, however, if a campaign social media page is converted/renamed into an elected official social media page it would be reclassified as an Elected Official Page. The following guidance is for City employees who decide to have a personal social media account and who decide to comment on or share posts about City business: 1. Use a disclaimer such as: “This is the personal (or campaign) page of [official/employee]” or “the views expressed are strictly my own and do not reflect or represent the views of my employer.” 2. Employees shall not use or disclose any information, photographs, video, or other recording obtained or accessible as a result of employment or appointment with the City without the express authorization of the City Manager and/or their authorized designee. 3. Employees may share or repost City information, such as updates on leaf pickup, City events, public meetings, emergency notices, and other relevant announcements, to help keep the community informed. PROFESSIONAL PAGES The City recognizes two types of professional social media accounts used for City-related communication: City-Controlled Pages and Elected Official Pages. By law, both are considered tools for public engagement and must reflect the values, transparency, and professionalism expected of public service. These pages are distinct from personal or campaign accounts. City-Controlled Pages are social media accounts created, owned, and managed by the City. These accounts represent the City as a whole, its departments, specific leadership positions, or specific initiatives, and are used to provide public information, communicate City services, and promote community events. All City-related communication through these social media pages shall remain professional in nature and should always be conducted in accordance with this Policy and the City’s Community Engagement Handbook. All content must maintain neutrality, and comply with legal standards for public communication, including accessibility, records retention, and privacy policies. All City- Controlled pages must be registered as outlined below. City-Controlled Pages shall not be used for political purposes, to conduct private transactions, or to engage in private business activities. Inappropriate use of City-Controlled social media can be grounds for disciplinary action. Only individuals authorized by the City may publish content to a City website or City social media account. Page 1 of 5 Examples of these accounts include: City of Muskegon Government on Facebook, Muskegon City Parks & Recreation on Instagram, and the Muskegon Farmers Market on Facebook. Elected Official Pages are social media accounts created and managed by elected officials (e.g., Mayor, City Commissioners) in their formal, public roles. Among other purposes, these accounts are used to share information and engage with the public on topics related to their duties within the City. Although Elected Official Pages are not subject to internal City oversight, elected officials are individually responsible for managing these accounts in accordance with applicable laws. Content that involves the discussion or facilitation of City business may be considered public record and subject to the Freedom of Information Act (FOIA) or the Open Meetings Act (OMA). Improper use—such as blocking constituents, deleting comments based on viewpoint, or mixing political campaigning with public duties—can create legal liability for both the official and the City. Elected officials are encouraged to clearly distinguish these pages from personal pages, and to understand the legal risks and responsibilities that come with using social media in an official capacity. REGISTERED CITY PAGES All City-Controlled social media sites shall be listed on one page on the City’s website. The link to that webpage is: https://muskegon-mi.gov/social-media-accounts/ REGISTERING A NEW PAGE All City-Controlled social media sites shall be (1) approved by the City Manager and/or designee, (2) published using approved social networking platforms and tools, and (3) be administered by the approved staff member(s). The City Manager and/or their designee, and the IT department, will be granted administrative access to all City-controlled social media pages. DEREGISTERING AN EXISTING PAGE If a City-Controlled social media page is no longer of use, (1) notify the City Manager and/or designee. (2) Ensure records have been archived according to City guidelines. (3) Set a timeline for deactivating the account. (4) Develop a farewell message to post on the account that includes when the account will be closed and where followers can go for information in the future. (5) Consult with the Community Engagement Manager to determine whether to protect the account name by keeping it active to prevent use of the City’s name for improper purposes. If a decision is made to protect the account name, take all necessary action to do so. (6) Unpublish or delete the page. (7) Update the list of official social media accounts listed online on https://muskegon-mi.gov/social- media-accounts/. Considerations for Deregistering: Considerations for deciding whether to deregister a City social media account may include, but are not limited to: • Merging an account into another City social media account. • It is no longer needed to accomplish a department’s goals. • It does not align with the City’s mission, vision, or values. • It does not comply with these procedures. • It is not currently being used or is being underutilized with no original posts for at least 60 days. • It is not being monitored. Page 2 of 5 OVERSIGHT AND ENFORCEMENT City-Controlled social media outlets or participating in social media features on City websites shall maintain a high level of ethical conduct and professional decorum. Failure to do so is grounds for revoking the privilege to participate in City social media sites or other social media features. Information shall be presented following professional standards for good grammar, spelling, brevity, clarity and accuracy, and avoid jargon, obscure terminology, or acronyms. City-Controlled sites shall be clear and precise and follow industry best practices for posting updates. All content posted to City-Controlled social media should be: 1. Relevant – Information that engages residents and pertains to their daily lives 2. Timely – Pertains to deadlines, upcoming events, or current news 3. Actionable – Prompts residents to take action 4. Informative – Posts should encourage residents to visit a specific City webpage for additional details, resources, or updates related to the content shared. Social media shall not be used to circumvent other City communication policies, including news media policy requirements. City- controlled pages shall not publish information on any social media sites that include: 1. Confidential information 2. Copyright violations 3. Profanity, racist, sexist, or derogatory content or comments 4. Partisan political views 5. Commercial endorsements or SPAM Time of Use: City-Controlled social media accounts are not monitored 24/7, and as such, posts and responses should not be immediately expected. Accounts are traditionally monitored during normal business hours, designated as Monday-Thursday from 7:30 a.m. to 5:30 p.m., excluding holidays. COMMENT AND PRIVATE MESSAGE GUIDELINES City-controlled pages shall decide and be consistent with their commenting and private message guidelines. Whether comments or private messages are allowed or not, the pages shall remain consistent. If comments are turned off on one post, they shall always be turned off on all posts when possible. Acknowledging that the “comment off function” is manual, and happens after the post is made, there is potential for a comment or two to be posted before the comment function is turned off. If that happens and a few comments are made, continue to turn the comments off and comment as the page to notify of the comment guidelines outlined in this policy. If the comment function is accidently not turned off and many comments are made, leave the commenting feature on for that post. City-Controlled pages that allow comments may reply to comments or questions as long as it’s following archiving rules and this policy. It’s encouraged that comments link back to information on an official City website. Refer to the “Moderation of Third-Party Content” section for commenting removal guidelines. SOCIAL MEDIA ACCOUNT AUDITS Annual audits of City-Controlled account activity and the effectiveness of the content being posted will be performed by the Community Engagement Manager in collaboration with the staff managing the page(s). The Department Director, or their designee, should confirm that City social media content moderation is regularly occurring to ensure that sites are active, that content is engaging, and that content posted in violation of this policy is handled appropriately. For purposes of this policy, “active” refers to a page having been posted to at least once weekly; and “engaging” refers to views, reach, and interaction with the posts. Page 3 of 5 RETENTION Social media sites are subject to local, state, and federal laws, including Michigan’s Freedom of Information Act (FOIA). Any content produced or maintained on social media sites, including communication posted by the City and communication received from citizens, is a public record. The Information Technology Department shall preserve records under the relevant records retention schedule in a format that preserves the integrity of the original record and is easily producible. Furthermore, the retention of social media records shall fulfill the following requirements: 1. Social media records are captured in a continuous, automated fashion throughout the day to minimize the potential loss of data due to deletion and/or changes on the social networking site. 2. Social media records are maintained in an authentic format (i.e. ideally the native technical format provided by the social network, such as XML or JSON) along with complete metadata. 3. Social media records are archived in a system that preserves the context of communications, including conversation threads and rich media, to ensure completeness and availability of relevant information when records are accessed. 4. Social media records are indexed based on specific criteria such as date, content type, and keywords to ensure that records can be quickly located and produced in an appropriate format for distribution (e.g. PDF). 5. Each employee who administers one or more social networking sites on behalf of the City has self-service, read-only access to search and produce relevant social media records to fulfill public information and legal discovery requests as needed. The City utilizes an automated archiving solution for all City-controlled social media sites to comply with applicable public records law and fulfill the above record retention requirements. The City’s archive is available through the Information Technology Department. Page 4 of 5 EXTERNAL POLICY The following guidelines shall be displayed to users on all social media sites or made available on the City’s website and be linked on social media pages. Time of Use: City-controlled social media accounts are not monitored 24/7, and as such, posts and responses should not be immediately expected. Accounts are traditionally monitored during normal business hours, designated as Monday-Thursday from 7:30 a.m. to 5:30 p.m., excluding holidays. MODERATION OF THIRD-PARTY CONTENT City-controlled social media sites serve as a limited public forum and all content published is subject to monitoring. The City- Controlled social media platforms are intended primarily for one-way communication of City information. Two-way communication should be discouraged where possible. Social media is not to be used for emergency communications with the City, such as reporting crimes or hazardous conditions. Such reports shall be made through designated official channels such as 911. Under no circumstance should users be blocked from City-Controlled social media accounts. If suspicious activity is noted, staff should report it directly to the social media platform. User-generated posts (comments) will be rejected or removed (if possible) when the content: 1. Contains obscenity or material that appeals to the prurient interest 2. Contains personal identifying information or sensitive personal information 3. Is threatening, harassing, defamatory, fraudulent, or discriminatory 4. Incites or promotes violence or illegal activities 5. Contains information that reasonably could compromise individual or public safety 6. False or misleading commercial speech or spam PUBLIC RECORDS LAW Social media sites are subject to applicable public records laws. Any content maintained in a social media format related to City business, including communication posted by the City and communication received from citizens, is a public record. The Department maintaining the site is responsible for responding completely and accurately to any public records request for social media content. Document edit notes Action Person Date Change New Deborah Sweet 6/10/25 Commission approved policy Page 5 of 5
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