@StateDept “Consolidates” Regulations for Official Communication Using Social Media

Posted: 3:19 am ET
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We previously blogged about the use of social media in State Department official communication back in February (see @StateDept Issues Guidance For Official Communication Using Social Media, What’s Missing?). On August 24, the State Department updated its guidance for official communication using social media. “To engage on social media in an official capacity, personnel must use an account created specifically for official use that is separate from an account used for private, personal use.”  The guidance also notes that “all Department social media sites used for official public communications must be registered by visiting the Social Media Account Registry on Diplopedia.”  The change transmittal notes that this change “consolidates regulations concerning social media for official public diplomacy and public affairs purposes.”

Per Foreign Affairs Manual 10 FAM 180:

a. Senior officials and other employees whose positions make it appropriate for them to engage in official communications on behalf of the Department over social media (“Department social media spokespersons”) must not use personal social media accounts to do so.  They must use official social media accounts, created and owned by the Department.

(1)  Department social media spokespersons must be instructed before they begin their positions that they will not be able to use their personal social media accounts for official communications, and that content on personal social media accounts must comply with 3 FAM 4176.  Forwarding, linking to, or otherwise reposting official content on a personal social media account will not ordinarily constitute official communications if the content was first released on an official platform, provided that it is clear from the circumstances that the personal social media account is not being used to communicate on behalf of the Department.

(2)  When Department social media spokespersons begin their positions, they are provided access to official social media accounts, and they will lose access to those accounts when they leave that position.  Whenever possible, the same account is passed from one incumbent in a position to the next.  As such, account names include only the office or position (e.g., @USEmbConsularManila, @USAmbManila); they do not include personal names.

(3)  Missions, bureaus, or offices must maintain a list of their authorized official social media accounts and the credentials for those accounts.  Accounts are created in accordance with 5 FAM 793.

b. In order to put a “human face” on the Department’s social media presence, Department social media spokespersons are authorized, but not required, to post certain kinds of personal content to their official accounts (e.g., posts about family news, pictures of pets, discussions of hobbies).  This personal content may be considered official communications and must comply with, among other things, restrictions on partisan political activities, endorsements of commercial goods or services, fundraising and solicitations, official actions affecting financial interests, and the publication of information that could compromise the security of the individual or others.  See 3 FAM 4175.2, Content of Official Capacity Public Communications, for additional guidance on content of official communications.

c.  All accounts that have been used for official communications are considered Department accounts, and are either retained by the Department for use by the next incumbent or retired in accordance with applicable records disposition schedules, as appropriate.  The content of such accounts is also retired in accordance with applicable records disposition schedules.

The new guidance also include a section on impersonations on social media; the regs make a distinction with parody accounts (good news Rexxon Drillerson (@RexxonDrill), but have the 10 FAM 184 handy).

a. Impersonations, or the creation of an account that is intended to be mistaken for another account, are not permitted on most major U.S.-based social media platforms, including Facebook and Twitter.  International Information Programs’ (IIP’s) Digital Support and Training Division is responsible for coordinating with U.S.-based third-party social media platforms to assist Department personnel in addressing situations where sites or accounts are impersonating official U.S. Government sites or accounts, including seeking removal of imposter accounts in an expedited manner.  Impersonation accounts are not the same as parody accounts.  Parody accounts pretend to be another account but for humor, satire, or other reasons that rely upon the viewer’s ability to tell that the account is not real, and they are generally permitted under platforms’ Terms of Service.

b. If you determine that there is an impersonation account on Facebook, you must file a ticket with Facebook and then email IIP’s Digital Support and Training Division at IIPSMS@state.gov with relevant details for documentation so that the ticket may be elevated with Facebook.

c.  If you determine that there is an impersonation account on Twitter, you must report the imposter to Twitter using this form and forward the autoreply email from Twitter, including the ticket number, to IIPSMS@state.gov to expedite the removal process with Twitter.

d. If you determine there is an impersonation account on another platform, you must follow that platform’s reporting guidelines and notify IIPSMS@state.gov.

e. You must not interact with or acknowledge the impersonator to avoid encouraging further activity.

What this consolidated guidance still does not include is what happens when “senior officials and other employees”, both career and political appointees do not comply with 10 FAM 180.  What if they refuse to switch from a personal account to an official account? Who will compel them?  And if State can’t compel them, how do you archive official communication from their personal social media account?

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Twitter Is a Cocktail Party, Not a Press Conference – But What Happened to 3 FAM 4170?

— Domani Spero
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 Updated 12/16/14 at 9:45 pm: We understand from the “R” shop that 3 FAM 4170 is in clearance now and something about “third time’s a charm!” What’s that about?

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The December issue of the Foreign Service Journal includes a Speaking Out piece by FSO Wren Elhai, Twitter Is a Cocktail Party, Not a Press Conference (or, Social Media for Reporting Officers). The author is currently serving in the political-economic section of Consulate General Karachi. Prior to joining the State Department, he worked at the Center for Global Development, a D.C.-based think-tank, as a policy analyst where he also ran the Center’s Twitter and Facebook pages. Excerpt below:

Current Foreign Affairs Manual regulations require any State Department employee posting anything to a social media site that relates to a matter “of official concern” to go through the same clearance process that would govern a media appearance or a published op-ed.

This is a shockingly vague rule, one that I have been told in training covers even posting quotes from official State Department statements or links to articles that support U.S. policy. It is a rule so vague that any diplomat with a Facebook account will confirm that nearly every one of us violates it on a daily basis.

If you think of Twitter as the digital equivalent of a newspaper, then it makes sense to try to maintain control over what diplomats say there. However, if Twitter is a digital cocktail party, that’s an untenable position. No one would even consider asking diplomats to pre-clear everything they say to people they meet at public events—let alone to seek press office clearance before starting a conversation with a potential contact.

We are paid to know U.S. foreign policy, to present and defend our positions, and to not embarrass ourselves when we open our mouths in public. We are trusted to speak tactfully and to know what topics are best discussed in other settings.

Our policy should treat our interactions online and in the real world on an even footing. Yes, there will be rare occasions when diplomats speak undiplomatically and, just as when this happens in the real world, those diplomats should face consequences.

But just as we don’t limit ourselves to talking about the weather at receptions, we should be able to present U.S. policy and engage with contacts online. To meet people, we need to show up for the party.

Read in full via FSJ here.

On the topic of consequences, Sir James Bevan KCMG, UK High Commissioner to India recently gave a speech to a group of journalists that’s related to this, particularly on how one might be a bit boring on Twitter, and for good reasons:

And we diplomats sometimes have to behave a bit differently from you journalists, or at least have to pretend that we do. There are things which you can do and say which we diplomats cannot, lest we provide you with copy that is good for you but bad for us. 

Some of you have said that my Twitter account @HCJamesBevan is a little bit boring. There’s a reason for that: I like my job and I want to keep it. For a diplomat, being too interesting on Twitter is the quickest way to get sacked. I like India and I want to stay here.

 

Back to the article, the author of the FSJ piece has cited 5 FAM 790 Using Social Media (pdf) on his article, the guidance first issued in June 2010. You might, however, want to check out 3 FAM 4172.1-3 (pdf) Review of Materials Prepared in an Employee’s Private Capacity, which includes matters of “official concern.”  It does look like 3 FAM 4170, the regs for Official Clearance of Speaking, Writing, and Teaching (pdf) has not been updated since 2009, but right now, that’s the official rules.

This past June, AFSA told its members that for more than a year it has been negotiating a revision to the current Foreign Affairs Manual regulations governing public speaking and writing (3 FAM 4170).

“As mentioned in our 2013 Annual Report, our focus has been to accommodate the rise of social media and protect the employee’s ability to publish. We have emphasized the importance of a State Department response to clearance requests within a defined period of time (30 days or less). For those items requiring interagency review, our goal is to increase transparency, communication and oversight.  We look forward to finalizing the negotiations on the FAM chapter soon—stay tuned for its release.”

This long awaited update to 3 FAM 4170 has been in draft mode since 2012 (see State Dept to Rewrite Media Engagement Rules for Employees in Wake of Van Buren Affair. Also check out a related piece we did in February 2013 (see Social Media Schizophrenia Continues on Background, and Oh, Stuff That Loophole, Ey?).

Hey, is it true that 3 FAM 4172.1-7  also known as the Peter Van Buren clause is nowhere to be found in the new version?

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