Understand best practice for engaging with your social media community.
Social media is not a one-way broadcast tool, but a platform for authentic, two-way conversations. If you’re publishing content, you need to moderate all comments and respond to legitimate comments.
As an account owner, your agency is likely to be considered the publisher (for the purposes of defamation) of comments left on your posts by third parties, and so you could be exposed to liability in defamation because of those comments. You may also be exposed to liability in contexts other than defamation.
To reduce the risk of exposing your agency to liability, you should ensure you follow the steps in this section.
Establish community guidelines
To ensure you can moderate your community effectively and maintain a safe space, you should have community guidelines in place. These guidelines must be accessible to anyone who visits your account profile.
Some platforms provide a section for you to share your community guidelines. If this section doesn’t exist, provide a link to your community guidelines somewhere on your social media page.
As a team, decide which of the following approaches you will use for community management:
- Active moderation — engaging with the majority of comments can imply that you endorse comments on your page. This could also include engaging with comments found through social listening that don’t @mention you. Best practice community management is via active moderation.
- Alert-only moderation — engaging only if commenters bring something to your attention by @mentioning you.
- Hands off moderation — disabling comments and messaging completely.
Your community guidelines should cover:
- the department or agency that manages the page
- your approach to community management (active/alert-only/hands off)
- hours that you monitor the page and expected response times
- an explanation that the page is apolitical
- acceptable conduct on the page (for example, no swearing, no bullying, no defaming, etc)
- what will happen if someone breaches the guidelines (for example, hiding comments, blocking, temporary suspension, banning, etc.)
- how to get in contact with the department or agency
- when the guidelines were last updated.
NSW Government Facebook community guidelines may be used as a template.
Actively monitor your channels
- Establish a frequency that you will check your channels. As a guide:
- high-visibility, high-risk and high-traffic accounts should check-in multiple times a day to minimise risk
- customer-service-based channels should respond to inbound queries as quickly as possible
- smaller, slower accounts might only need to be checked once every couple of days.
- If you use a social media management tool to respond to comments, make sure you regularly check your page natively so nothing gets missed.
- Rely on your community guidelines to support you if you need to:
- hide or delete comments where they are in breach (instead of deleting)
- block repeat offenders as a last resort (this is recommended only in extreme cases).
- Use a strong profanity filter, where possible, so swearing doesn’t appear in comments on/replies to your posts. If you’d like a copy of the NSW Government Facebook profanity filter list, contact the NSW Government Social Media team.
- Respond to as many reasonable queries as possible, even those that don’t directly tag your account (you can find these using social listening).
Respond to a social media crisis
When facing a potential crisis, consider taking the following actions:
- If you believe that a person engaging with your account is a danger to themselves or others, contact the NSW Police.
- Report content or comments that are bullying, defamatory, or dangerous to the platform. Then hide or delete the content or comments (if possible).
- If asked to delete allegedly defamatory content, keep a record of what was posted, remove it quickly and consider seeking legal advice.
- If asked to delete content that you believe should stay posted, work with the stakeholder to understand why they think it should be deleted.
- Seek advice and assistance from your legal team and subject matter experts, where appropriate.
Put the customer first
Customers today expect more secure, transparent, accessible, and responsive services from government.
On social media, you should:
- answer legitimate queries transparently
- use plain English
- tailor responses to individual queries (as opposed to linking off to websites where customers need to read through the information to find their answer)
- make sure everything you post is accessible.
Set expectations for how staff should act on social media
Staff should also be aware that they are subject to the same community guidelines as everyone else when interacting with NSW Government social media channels.
Your department should have a social media policy which sets out appropriate behaviour for staff. If your department doesn’t have a social media policy, refer to your Department’s Code of Conduct while you work on creating one.
See guidance on how to write a social media policy for your department or agency.
Allocate sufficient resources
Allocate dedicated resources to monitor your channels, including comment moderation, social listening, and community management.
If dedicated resources aren't available and community comments present a high risk, consider hiring a (carefully vetted) external agency to monitor comments.
If your account is targeted to children, there may be specific legal or regulatory requirements. You may need to employ moderators who:
- have a Working With Children Check or National Police Check
- are trained to identify suspicious behaviour (for example, grooming or other predatory behaviour).
The Office of the eSafety Commissioner website provides guidelines on social media platforms or websites that may be directed towards children. Check with your department’s legal team if you think this is relevant to you.
Block posts and users that breach your policies
In line with your community management guidelines:
- report posts or comments that breach your policies and/or are defamatory to the platform
- block or ban users who make threatening, unacceptable, discriminatory, offensive, or defamatory comments.
Report unofficial or fake NSW Government pages to the platform and escalate to your platform account manager. If nothing is actioned, contact the NSW Government Social Media team.
Posting sensitive content
Generally, avoiding posting content because it may receive negative responses is not recommended. The community is welcome to share their views and have robust discussions. However, if your agency is planning on publishing content that is likely to attract potentially defamatory comments (for example, when mentioning or depicting an individual/individuals), you should consider taking additional measures to reduce the risk of attracting potentially defamatory comments. This may include allowing for additional temporary moderation resourcing or selecting placements where community engagement is not public (for example, 'stories').
If you choose to post something that is likely to elicit strong responses because it is an emotive issue or a sensitive/divisive topic:
- word the post carefully and with sensitivity to the subject matter
- test the post with customers (for example, A/B test two dark posts on Facebook to learn which wording/imagery works better)
- sense-check the post through your normal approvals process, including with subject matter experts
- anticipate what questions users will ask and draft answers to frequently asked questions (FAQs) ahead of posting
- seek approval from your legal, policy or media team, if in doubt
- know who you need to contact in the event an issue arises that requires escalating
- know when it’s time to pause (for example, during times of crisis, like bushfires, consider pausing non-essential social media activity, as being active might be viewed as insensitive)
- allow people to have their say, even if they’re critical of the NSW Government. Don’t censor unfavourable comments unless they breach the community guidelines.
Guidance from platforms
Check community management guidance for each platform.