4.1. ERMUSR 05-14-2019 Elk River
Municipal Utilities UTILITIES COMMISSION MEETING
TO: FROM:
ERMU Commission Michelle Canterbury—Executive Administrative Manager
MEETING DATE: AGENDA ITEM NUMBER:
May 14, 2019 4.1
SUBJECT:
Communications Policy
ACTION REQUESTED:
None.
BACKGROUND:
On October 10, 2017, the Commission adopted Governance Policy G.4p External
Communications. The policy delegated responsibility to the General Manager to adopt
appropriate management policies and procedures to ensure that ERMU management and staff
is fully aware of their individual responsibilities and limitations with respect to information
management and external communications. The management policies were to include a
communications policy.
DISCUSSION:
In an effort to provide accurate and timely information in a professional manner in accordance
with law regarding public information, records retention, and data practices, a communications
policy has been developed. This internal management policy provides general guidelines for
official ERMU external communications including: media relations, and electronic
communication platforms such as ERMU's website and social media sites.The policy also
addresses how to speak on behalf of ERMU, and guidelines for employees to consider when
personally communicating with the public.
As communication methods for social media are ever-emerging, staff has made an effort to
keep the social media portion of the policy more generalized to accommodate the multitude of
social networking, and video and photo sharing sites that we may choose to utilize.This portion
of the policy also outlines the monitoring of social media sites, when and how to respond to
comments, expectations for response time, and required disclaimers.
Also addressed in the policy is who is authorized to communicate on behalf of ERMU in
interviews, publications, news releases, on social media sites, and related communications, and
how that authority may be designated.
ATTACHMENTS:
• ERMU Management Policy—A.26—Communications Policy—For Reference Only
• ERMU Commission Policy—G.4p— External Communications— For Reference Only
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Elk River
Municipal Utilities MANAGEMENT POLICY
Section: Category:
Management Administration Policies
Policy Reference: Policy Title:
A.26 Communications Policy
PURPOSE:
Elk River Municipal Utilities (ERMU) strives to openly provide accurate and timely information
in a professional manner in accordance with law regarding public information, records retention,
and data practices. The intent is to ensure all communications accurately reflect factual
information and is consistent with, and relevant to, our mission,vision,value, and fundamentals.
This policy provides guidelines for external ERMU communications including:
• Media relations such as requests for interviews, news releases, and media inquiries.
• Electronic materials such as websites and social media sites.
ERMU also recognizes employees may sometimes comment on utility matters outside of their
official roles as an employee of ERMU. Therefore,this policy provides guidelines for employees
when communicating as a private citizen on matters pertaining to ERMU business.
GUIDELINES FOR OFFICIAL ERMU COMMUNICATIONS:
General Requests
All staff is responsible for communicating routine information to the public in relation to their
specific job duties. Requests for private data or information outside the scope of an individual's
job duties should be routed to the appropriate department head or to the data practices authority.
Media Requests
With the exception of routine events and basic information which is readily available to the
public, all requests for interviews or information from the media are to be routed through the
general manager or his/her designee. Media requests include anything intended to be published
or viewable to others such as television, radio, newspapers,newsletters, and websites.
Responding to Media Requests
If the request is regarding information about ERMU personnel it is to be directed to the finance
& office manager. Other requests such as potential litigation, controversial issues, an opinion on
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ERMU Management Policy—A.26 Communications Policy
a utility matter, or if you are unsure if it is a"routine" question, should be forwarded to your
supervisor.
An appropriate response would be, "I'm sorry, I don't have the full information regarding that
issue. Let me take some basic information and submit your request to the appropriate person who
will get back to you as soon as he/she can."Ask the media representative for the following:
• Name and organization they are representing
• Questions
• Deadline
• Contact information
Communicating on Behalf of ERMU
Only the general manager, or his/her designee, or a designee of the board, are authorized to
communicate on behalf of ERMU in interviews,publications, news releases, on social media
sites, and related communications. If designated to communicate on behalf of the ERMU:
• Employees or Commissioners shall identify themselves as a representative of ERMU.
• All information must be respectful, professional,truthful, and accurate.
• Mistakes: If an error is made, corrections should be sincere and as timely as possible.
• Do not engage in speculation.
• Do not speak critically about ERMU or others involved in a matter.
• Do not speak on topics you are not designated to speak upon.
• The general manager, or his/her designee, will be the spokesperson in the event of an
emergency or disaster.
• Personal opinions don't belong in official ERMU statements.
GUIDELINES FOR PERSONAL COMMUNICATIONS:
It is important to remember personal communications may reflect on ERMU, especially when
commenting on utilities' business. The following guidelines apply to personal communications
including social media, newspaper letters to the editor,reader's comments in newspapers, and
personal endorsements.
• Remember that what you write is public and will be for a very long time. It may also
be spread to large audiences. Use common sense when using email or social media
sites. It is a good idea to refrain from sending or posting information that you would
not want your supervisor or other employees to read, or that you would be
embarrassed to see in the newspaper.
• ERMU expects its employees to be truthful, courteous, and respectful towards
supervisors, co-workers, citizens, customers, and other persons associated with the
utility. Do not engage in name-calling or personal attacks.
• If you publish something related to ERMU business, identify yourself and use a
disclaimer such as, "I am an employee of ERMU. However,these are my own
opinions and do not represent those of ERMU."
• ERMU resources,working time, or official utility positions cannot be used for
personal profit or business interests, or to participate in personal political activity. For
example, a lineworker shall not use the ERMU logo, email, or working time to
promote his/her side business as an electrician.
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ERMU Management Policy—A.26 Communications Policy
• Personal social media account names or email names should not be tied to ERMU.
GUIDELINES FOR SOCIAL MEDIA:
ERMU believes social media is an important and effective way to reach new audiences and
communicate important information to the community and its stakeholders in a timely manner.
ERMU has an official Facebook, Twitter, Linkedln, Instagram, and YouTube page.Additionally,
ERMU also maintains an official website. These official social media communication tools have
been created with approval by the general manager and are overseen by the executive
administrative manager. All current and future social media sites that represent ERMU must
adhere to the following general guidelines:
• The type of page is"government."
• The communications coordinator will standardize and provide all site displays to
include the ERMU logo and other pertinent information.
• Will be based on a template to include ERMU branding and identity style. The
communications coordinator will provide the template.
• A social media application shall not be used unless it serves a business purpose, adds
to the user experience, comes from a trusted source, and is approved by the executive
administrative manager. ERMU wishes to ensure that sanctioned applications are kept
to a sustainable number, policies are followed, and branding is consistent.
• All passwords must be provided to the executive administrative manager.
• Any new social media applications proposed for ERMU use must be approved by the
executive administrative manager, IT, and the appropriate department head.
• Page visitors shall be notified that the intended page purpose is to serve as a public
communication tool and all page information and its list of fans are public records
subject to the Minnesota Government Data Practices Act.
• Page visitors shall be informed that ERMU reserves the right to remove any
comments that include offensive language.
• Posted photos or videos of people require permission. Do not post photos that infringe
on trademarks, copyrights, etc. Give appropriate photo/video credit.
• Do not post information affiliating or advocating ERMU with/for a political party or
candidate.
• Where possible,posted content should contain links redirecting users to ERMU's
official website for in-depth information, forms, etc.
• Postings shall be grammatically correct.
• ERMU reserves the right to shut down any social media account due to violations of
law or ERMU policies, and/or employee termination.
• Adhere to areas of your business expertise and provide your perspective on your
current activities and those of your industry.
• Always think before posting; if it causes you to pause or question if it is appropriate,
it most likely should not be posted.
• Be aware that by identifying yourself as an ERMU employee you are creating
perceptions about yourself and about the utility. Be sure all content associated with
you is consistent with your work and ERMU's professional standards.
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ERMU Management Policy—A.26 Communications Policy
Monitoring Social Media Pages
Successful social media pages require monitoring. Each department utilizing social media tools
shall appoint an administrator responsible for monitoring. Due to the nature of our business, it is
ERMU's philosophy to handle any conversations or debates offline via a phone call or email.
That being said,the following guidelines have been established to help determine when and how
to respond.
When and How to Respond
• If the person has a question, complaint, or wants to debate:
If the person making the comment is an ERMU customer,provide their contact
information to the department head that can best address their comment offline. A
general response to the post should also be made acknowledging the customer's
question, or thanking them for their feedback, and telling them that someone will be
personally reaching out to them to address their question or complaint. Provide the
title of the individual that will be contacting them.
If the person making the comment is not an ERMU customer, or their contact
information is not available, a general response to the post should be made
acknowledging their question, or thanking them for their feedback, and encouraging
them to contact the specific department head that can best address their question or
complaint. Provide the title of the individual they should contact along with ERMU's
general phone number.
• If the person leaves a general comment:
A comment such as"This video was informative," requires no response.
Accuracy and Timeliness
ERMU shall make every effort to ensure the accuracy and timeliness of posted information
barring factors beyond control including, but not limited to, unauthorized modification of data,
transmission errors,browser incompatibilities, information, etc. which can affect the quality of
displayed information. ERMU does not guarantee the accuracy of the information provided on its
tools and is not liable for reliance on this information.
ERMU's timeliness with posts and responses to comments may also vary based on staff
availability,therefore a disclaimer shall be posted on any social media site, stating:
This social media page is intended to provide information in a timely manner to a wide audience
and not as an in-depth or complete source of information. It is an evolving supplement to the
official ERMU website,press releases, and in person communications. Responses will typically
be posted within office hours and within varying parameters of staff availability. For these
reasons, staff may not need to respond to every comment or question posted on the social media
site.
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ERMU Management Policy—A.26 Communications Policy
Administrators responsible for monitoring social media pages may set up automatic email
notification when someone posts a comment to a social media site.
Comments
The following disclaimer shall be posted on all pages allowing comments:
Please note comments expressed on the ERMU's social media tools do not reflect the opinions or
positions of ERMU, its employees, or its appointed officials. ERMU reserves the right to remove
any comments, questions, or postings containing:
• profane language or content
• personal attacks, harassments, or threats against any individual or organization
• content that promotes,fosters or perpetuates discrimination on the basis of race,
creed, color, age, religion, gender, marital status, status with regard to public
assistance, national origin,physical or mental disability or sexual orientation
• content not topically related to the particular social medium article being commented
upon
• support for or against any political campaign or ballot measures
• copyright infringements or other legal violations
• solicitations of commerce
• sexual content or links to sexual content
• conduct or encouragement of illegal activity
• information that may tend to compromise the safety or security of the public or public
systems
• content that violates a legal ownership interest of any other party
ERMU reserves the right to restrict or remove any content deemed in violation of this social
media policy or any applicable law. Often commentators will police themselves;therefore,
comments should be removed by ERMU only as a last resort. All removed comments will be
saved in a"removed comments"folder for data practices purposes. When a comment is
removed, a note will be posted in its place explaining the violation.
Records Retention
Social media sites are subject to the General Records Retention Schedule for Minnesota Cities
and the executive administrative manager shall ensure all data required to be maintained
pursuant to the retention schedule for the required retention period are preserved in a format
maintaining the integrity of the original record and is easily accessible. All ERMU social media
sites shall comply with ERMU policies.
Data Ownership
All social media communications or messages composed, sent, or received on ERMU equipment
in an official capacity is the property of ERMU and will be subject to the Minnesota Government
Data Practices Act. This law classifies information as available to the public upon request.
ERMU also maintains the sole property rights to any image, video, or audio captured while an
ERMU employee is representing ERMU in any capacity. ERMU retains the right to monitor
employee's social media use on ERMU equipment and will exercise its rights as necessary.
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Users should have no expectation of privacy. Social media is not a secure means of
communication.
Data Practices
Non-public or confidential data shall not be posted per the Minnesota Government Data
Practices Act. ERMU's data practices compliance official is responsible for responding
completely and accurately to any public records request on social media.
Violations of the Policy and Discipline
Employees may be disciplined in accordance with ERMU's Employee Manual for violations of
this policy.
ERMU OFFICAL INTERNET/SOCIAL MEDIA SITES:
Facebook
https://www.facebook.com/elkrivermunicipalutilities/
Twitter
https://www.twitter.com/ERMU MN
Instagram
https://www.instagram.com/ermu mn/
Linkedln
https://www.linkedin.com/company/elk-river-municipal-utilities
Website
https://www.ermumn.com
YouTube
https://www.youtube.com/channel/UCEGlUbysRkewnPy6Qaa-YPw
POLICY HISTORY:
Established May 14, 2019
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Elk River
Municipal Utilities COMMISSION POLICY
Section: Category:
Governance Delegation to Mangement
Policy Reference: Policy Title:
G.4p External Communications
PURPOSE:
With this policy,the Commission sets forth its expectations for the General Manager
concerning ERMU's external communications.
POLICY:
The Commission expects the General Manager, or an authorized designee of the General
Manager,to be the point of contact for communications between ERMU and external interests
including the news media,state or federal governmental and regulatory bodies, and the elected or
appointed leaders of governmental jurisdictions in which ERMU operates. Such designation
does not preclude the Commission Chair(or other Commission officer or member specifically
designated by the Commission)from speaking on behalf of the Commission concerning matters
of Commission policy or Commission action. The Commission expects all external
communications to be reasonably consistent,timely,accurate, and clearly stated,with appropriate
protection of any information that has been designated as confidential.
Consistent with the above general statement,the General Manager shall:
1. Protect information that has been designated confidential,except in those situations where the
release of such information has been explicitly authorized by the Commission or required by
law or regulation, including the Minnesota Data Practices Act(Minnesota Statutes, Chapter
13).
2. Adopt appropriate management policies and procedures to ensure that ERMU
management and staff are fully aware of their individual responsibilities and limitations
with respect to information management and external communications. These policies will
include a data practices policy; a records management policy; and a communications
policy.
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ERMU Commission Policy—G.4p External Communications
Note: See Commission Member Role,Responsibilities, and Orientation; Commission
Member Conduct; and Commission Officer Roles,Responsibilities and Succession for
related policy provisions concerning external communications by Commission Members and
Commission Officers.
POLICY HISTORY:
Adopted October 10, 2017
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