Exploring the Charity Commission's social media guidance

At the beginning of 2023, the Charity Commission published draft guidance for charities on their use of social media. Charities, trustees, and individuals were invited to feedback on the draft guidance in the consultation period, which ran from 17 January to 14 March 2023. 

Infrastructure bodies, NCVO, CharityComms, and the Chartered Institute of Fundraising convened their members in early March 2023 to discuss the draft guidance, to air concerns, and to help facilitate discussion around how best to respond to the consultation. 

There were a number of concerns raised, such as the onus on trustees to have oversight of social media channels (more operational than governance), the lack of practical templates and case study examples, concern over infringing on people’s right to freedom of expression, and the use of subjective language – for example, ‘problematic content’.

After receiving 396 responses to the draft consultation, the Charity Commission has now published the final guidance. They have also produced a helpful feedback summary of key themes and concerns arising from the consultation and the action they have taken as a result.

On the whole, the sector has reacted positively to how the Charity Commission incorporated the feedback into their final guidance document.

What the guidance means for charities

The guidance will help charities to create or update appropriate social media policies for their organisation. As NCVO’s CEO Sarah Vibert said in a Civil Society article, “These latest changes help ensure charities are able to effectively and efficiently maximise the opportunities that social media bring to ensure they are able to meet their charitable objectives.”

Key points in the guidance

Here are the key points from the guidance that you need to know about and potentially action.

Social media policy

The guidance states that organisations with a presence on social media should have a Social Media Policy.

The policy is not a ‘one size fits all’ and should be appropriate for the resources your charity has and the level of risk presented by using social media.

The guidance includes a checklist to help charities consider what to include, as well as a Social Media Policy template.

Managing potential risks

Your social media policy should set out, and make clear, what content should not be posted or shared. This could include content that is harmful or in breach of the law – for example, copyright law and defamation law.

It also recommends providing appropriate training for trustees, staff, and volunteers. 

Content posted or shared by your charity

Your social media policy needs to set out who is responsible for managing the organisation’s social media accounts and who can post or share content.

It advises having procedures in place to deal with a breach of the policy or if the content shared poses a significant reputational risk (a social media crisis). The guidance, however, does not link to any helpful Crisis Comms templates. Here’s one from CharityComms.

If there has been a serious incident, where significant loss or harm has occurred to the charity or the people it helps, it must be reported to the Commission.

Content posted by trustees, staff, or volunteers

The guidance clearly states that individuals have the right to exercise their freedom of expression, within the law, when using social media. It gives the example that a trustee can personally support a particular political party through their social media, whereas a charity cannot.

There is also no expectation for trustees to monitor the personal social media accounts of staff – a point that was implied in the draft guidance.

If trustees become aware of content being posted or shared by an individual that has a negative effect on the charity, they need to consider what action needs to be taken.

This should be guided by the charity’s social media policy. 

Moderating content posted by others

Engaging with people is what social media should be about. However, sometimes people will post inappropriate or harmful content on the charity’s own social media posts.

The guidance gives pointers on what to consider when assessing the risk, as well as encouraging charities to consider training and tools to help with moderation. 

Engaging on emotive topics

Lots of charities are involved in issues that provoke strong emotions in others. The guidance states that charities can engage in emotive topics on social media, as long as it is a way of achieving its charitable objectives and is in the charity’s best interest.

It recommends to plan appropriately, to consider the potential risks, and to inform key stakeholders of your plans.

It also encourages charities to consider the impact on staff, how you can support them if they have to deal with abuse or complaints, if your complaints procedure is fit for purpose, and any other rules or regulations you should adhere to – such as following rules set out by the Advertising Standards Authority.

Campaigning or political activity

The guidance confirms that charities can use social media to engage in political activity and campaigning, provided that they follow the rules as set out in the Campaigning and Political Activity guidance. In addition, they recommend that everyone knows the rules and that extra care is taken around elections.

Fundraising on social media

The guidance recognises the potential of social media to reach a wider audience and that this can attract criticism, of a fundraising campaign or door-to-door fundraising, for example. The Code of Fundraising Practice applies to fundraising on social media and the Commission expects charities to abide by the Code.

Staying safe online

The guidance links to helpful resources, produced by the National Cyber Security Centre, to help charities understand what to do if their accounts are hacked or fake accounts are set up in their name.

What is missing from the guidance

The guidance recognises that social media can have a negative impact on those who manage and moderate it and advises charities to consider "whether staff are getting the support they need from the charity, for example because of their experiences moderating others’ comments or criticisms".

Under the section ‘Engaging on emotive topics’, the guidance says charities should consider ‘the impact on your resources and staff, for example of receiving a significant number of complaints or negative attention. This should include how you will support staff in case they have to deal with complaints and online abuse.’

Unfortunately the guidance does not include any signposting to wellbeing resources or a Wellbeing Strategy template. It would be beneficial if they updated their guidance to include this, particularly as 24.9% of charity comms staff said that their role negatively impacted their mental health with 3.6% saying it impacted it very negatively, according to the CharityComms Salary & Organisational Survey 2022.