Village Social Media Policy

Statement of Purpose
The use of social media allows the Village of South Barrington to expand communications efforts with our community by providing additional avenues by which to share news releases, inform the public of projects, initiatives, general Village service information, and highlight events and positive media coverage. Social media allows the Village to share information in real time. It is the intent of this policy that social media platforms used by the Village are “limited public forums,” as defined by First Amendment case law, unless the Village, in its discretion, determines that a particular social media platform is to be a “government communication.”  Social media may also provide a two-way means by which to interact with residents, visitors, media, local business owners, and people who work in the Village

Forum Examples
Examples of social media that the Village may use include, but are not limited to: Facebook, Twitter, Instagram, LinkedIn, NextDoor, YouTube, photo and video sharing sites, virtual worlds, and other sites that allow interactive posting of information, images, video and comments.

Applicability
This policy shall apply to all Village departments as well as any affiliated government or non-government agency or official permitted by the Village to post on the Village’s social media sites. This policy applies to the use of social networking sites in the course of conducting official Village business and is not intended to address employee’s personal use of social media networking sites. Employees should also make themselves aware of Village policies pertaining to personal use of social media networking sites and the potential ways that such use could impact their employment with the Village.

Policy
The Village’s social media program involves establishing an online presence that offers the community various ways to receive Village updates and information. The choice of platforms the Village uses, does not use, or whether it continues to maintain an interactive social media presence remains at the discretion of the Village. The Village’s Administration Department is responsible for the creation, administration, updating and monitoring of official Village of South Barrington social media. No Village department shall create a separate social media account without the approval of the Village Administrator.

Postings on Village social media sites may only be made through official Village accounts that are recognizable as being affiliated with the Village. Official postings on Village social media sites shall only be made by Village employees authorized to post as a representative spokesperson of the Village. Village employees not authorized to act as a representative spokesperson shall not represent themselves as such if posting as a private citizen.

Authorized personnel shall not intentionally delete or hide comments left on the Village’s social media accounts by community members unless they are Prohibited Content as described hereinbelow, or do not qualify for First Amendment protection as determined in consultation with the Village Attorney. If authorized personnel have any questions as to whether content is prohibited, they should contact the Village Attorney.

Third party information from Village partners may be shared through social media as long as it conforms to the following guidelines:  sharing information about the programs and events that are Village-sponsored, a program of a Village board/commission, or that of our government partners are permitted; information on the Village’s website or through the Village’s communications channels for local organizations or businesses cannot be posted unless agreed upon in a sponsorship agreement for a Village-sponsored event.

Comments published on Village social media platforms are public. If you want to communicate with the Village in private or have a question you need the Village to answer, do not post to our social media sites. Instead, visit our website where you will find specific contact information to particular Village staff and officials. Communications made through social media posts will in no way constitute a legal or official notice or comment to the Village of South Barrington.

The Village’s social media sites are subject to State of Illinois Public Records Laws; therefore, content shall be managed, stored, retired, and deleted to comply with these laws.

Removal Protocols
The following summarizes the procedures for removing content from official Village social media accounts.  Its goals are to (1) ensure compliance with applicable laws, (2) preserve public trust, and (3) provide a clear, consistent process for authorized removals.  For purposes of this section, hiding content is the same as removal of content, where applicable.  The Village reserves the right to remove content it creates and to moderate public comments in accordance with this Social Media Policy.

Content posted to official Village social media may constitute a public record under the Illinois Local Records Act (50 ILCS 205/) and may be subject to disclosure under the Illinois Freedom of Information Act (5 ILCS 140/).  Public comment sections may be considered a limited public forum, requiring viewpoint-neutral moderation in accordance with the First Amendment to the United States Constitution.

Village-created posts may be removed for reasons including, but not limited to:

1. Factual inaccuracy that cannot be corrected through editing.
2. Duplication or outdated announcements.
3. Posts made in error or without authorization.
4. Replacement with updated information.
5. Compliance with a legal hold, settlement, or other legal obligation.

Public comments may be removed if they violate the Village’s Prohibited Content list hereinbelow.  Removal of public comments is based on objective, content-neutral criteria—not disagreement with the commenter’s viewpoint.

The removal procedure is as follows:

1. Preservation Before Removal: Prior to removal, staff must capture a screenshot or digital archive of the post/comment, including visible date, time, username, and any attached media; an archive must be stored in accordance with the Village’s records retention schedule and in compliance with the Local Records Act.
2. Authorization: Regarding Village-created content, removal may be authorized by the Village Administrator or designated Department Head; regarding public comment removal, removal must be authorized by the Village Administrator in consultation with the Village Attorney, where necessary.
3. Documentation: Village staff shall record the date/time of removal, the platform, the content removed, and the reason for removal, and maintain documentation for at least the retention period applicable to similar public records.
4. Notification (Optional): The Village may, at its sole discretion, post a brief note stating that content was removed for policy compliance, or directly notify the commenter if practicable.

Special Considerations regarding removal include the following:

1. Litigation Holds: If the content relates to pending or anticipated litigation, do not remove it without the Village Attorney’s approval.
2. FOIA Requests: If content is the subject of a pending FOIA request, do not remove it until the request is fulfilled and records are preserved.
3. Corrections vs. Removal: When feasible, in the Village’s sole discretion, correct or annotate existing content rather than deleting it outright.

Prohibited Content

Public posts and comments may not include any of the prohibited content listed below. Village social media account content and comments containing any of the following forms of content shall not be allowed for posting and shall be removed:

1. Comments unrelated to the particular Village post purportedly being commented upon.
2. Comments that promote, foster, or perpetuate discrimination on the basis of race, religion, gender, marital status, familial status, national origin, age, mental or physical disability, sexual orientation, gender identity, gender expression, source of income, or other protected status under applicable law.
3. Comments containing vulgar, offensive, profane, or physically threatening language, personal attacks, or unsupported accusations.
4. Language that promotes or provokes violence or unlawful harassment.
5. Content that violates any cyber-crime or other criminal law.
6. Information that may compromise the safety or security of the public or public systems.
7. Comments from children under 13 (to comply with the Children’s Online Privacy Protection Rule, “COPPA,” 16 CFR Part 312) – by posting on the City’s site, users acknowledge that they are at least 13 years old.
8. Photographs or videos unrelated to the particular post being commented upon.
9. Personal information of any person such as social security numbers, driver’s license numbers, bank accounts, address or telephone numbers.
10. Private information as defined by State or Federal statue, regulations, or written Village policies adopted in conformance with the law.
11. Spamming or repetitive content such as posting the same content more than two times in the same location. Links cannot be verified and are viewed as spam. Content viewed as spam will either be automatically removed or hidden by the social media site or will result in the comment being removed.
12. Sexual content or links to sexual content.
13. Solicitations of commercial sales or commercial links and comments that involve political campaigning or lobbying.
14. Conduct or encouragement of illegal activity.
15. Content that violates a legal ownership interest of any other party including trade secrets (information regarding the development of systems, processes, products and technology), internal reports, policies, procedures and confidential communications.
16. Content that defames any person, group, or organization.
17. Slanderous, libelous, malicious, offensive, threatening, profane, uncivil, or insulting language. References to the personality of individuals or personal attacks, insults, or threats will not be permitted.

Notice
Users and visitors to the Village’s social media accounts shall be notified that the intended purpose of the account is to serve as a mechanism for communicating Village news, services, and events, and certain social media accounts may constitute a limited public forum. By posting or commenting, users agree to the terms of use outlined in this policy, which will be posted to the Village’s website and linked to, as technology allows, from each of the Village’s social media accounts.

Time of Use
The Village of South Barrington’s social media accounts are not monitored 24/7. Comments are monitored only during normal business hours and thus information conveyed after hours will not be received until the next business day. We may not be able to remove comments that violate our policies right away but will take action as soon as practicable.

Accessibility
When possible, and as technology allows, staff will make every effort to ensure that photos and videos posted to social media accounts are accessible to all, including those with visual or auditory impairment, by using available alt text, closed captioning, or other assistive features.

Emergency Notice
As the Village’s social media accounts are not monitored 24/7, users are advised NOT to use the Village’s social media accounts to report a crime or emergency situation. Crime reports and requests for police, fire, or emergency medical assistance must be made by dialing 9-1-1.

Disclaimers
The Village of South Barrington does not guarantee that any information posted on its social media platforms is correct and disclaims any liability for any loss or damage resulting from reliance upon such information. The Village does not guarantee, and assumes no liability for, anything posted on our social media platforms by any person, employee or otherwise.

The Village of South Barrington has not evaluated the facts or information contained in public comments and does not endorse any position, product, business or non-official statement that may be on any of its social media sites.

Village Intellectual Property
The Village seal and any other departmental logos, designs, or symbols are the exclusive property of the Village of South Barrington and are legally protected. Such symbols, logos, or designs may not be used without the Village’s explicit permission.

Privacy
External social media platforms have their own privacy policies that visitors should be aware of. Links to the privacy policies of our social media platforms are as follows:

• Facebook privacy policy
• Instagram privacy policy
• NextDoor privacy policy
• LinkedIn privacy policy
• Twitter (X) privacy policy
• YouTube privacy policy
• Flickr privacy policy
• MailChimp privacy policy

Review and Updates
This policy will be reviewed annually by the Village Attorney and updated as needed to reflect changes in law, technology, or Village policy.

Effective Date
This policy is effective upon adoption by the Village Board.