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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 Page 1 of 1 350 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 Page 1 of 6 351 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. Page 2 of 6 352 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. Page 3 of 6 353 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. Page 4 of 6 354 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. Page 5 of 6 355 ERMU Management Policy—A.26 Communications Policy 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 Page 6 of 6 356 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. Page 1 of 2 357 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 Page 2 of 2 358