Common Rules for the Use of Social Media

Download the document as a pdf

1. About the policy Document

1.1. Adopted

The Common Rules for the Use of Social Media were established by RFSL’s congress on 11–13 May 2018.

1.2. Previous policy documents

These rules replace the social media policy adopted by RFSL’s congress in 2016.

1.3. Superior policy documents

Statutes of RFSL.

1.4. Purpose of policy document

The Common Rules for the Use of Social Media describe RFSL’s responsibilities, ways of working, and modes of expression in social media work. 

1.5. Organisations and individuals concerned

The Common Rules for the Use of Social Media apply to the national organisation, the branches, and the branches’ external operations. They do not apply to the private use of social media by elected representatives, activists, or employees. For elected representatives, the Common Rules for Elected Representatives within RFSL apply.

1.6. Delegations in the policy document

The common rules delegate (section 2.3) to the executive board the authority to decide on guidelines for how personal data shall be handled.

2. Provisions

2.1. Background

The internet creates many opportunities for spreading our message and interacting with our members and the world around us. Social media is the collective term for websites and mobile apps where people can interact in social networks and contribute user-generated content. Examples of social media include blogs, Facebook, Twitter, Instagram, YouTube, and Snapchat.

Social media offers RFSL as an organisation many opportunities, but also carries risks. Elected representatives, activists, and employees alike, as well as RFSL itself, should, in all use of social media, bear in mind that RFSL is an organisation subject to constant scrutiny, both by serious actors and by homophobic, transphobic, and racist individuals and organisations. It is therefore important to consider carefully how things are expressed and in what context. In this regard, the common rules may also be helpful to those who are not bound by them.

RFSL’s social media work is grounded in the federation’s purpose statement and shall contribute to a society characterised by diversity, openness, and respect for human differences, where everyone, regardless of sexual orientation or gender identity, and regardless of how they choose to express that orientation or identity, shall have equal rights and obligations, equal value, and equal opportunities to live and act.

In all use of social media, we shall treat everyone with respect and honour individuals’ personal integrity, regardless of, for example, gender, gender identity, gender expression, sexual orientation, age, ethnicity, religion or other belief, political opinion, health, HIV status, socioeconomic background, and functional ability. It is never acceptable to express, for example, racist opinions or jokes, or anything that gives the impression that RFSL does not respect others’ gender identity or identities, or sexual orientation. As a matter of course, we use the pronoun(s) and name(s) that people state they use.

2.2. Our Responsibilities

In social media work, there are a number of laws we are required to follow.

We must have the right to process personal data

Under the General Data Protection Regulation (GDPR), a legal basis is required for processing personal data. Legal basis means that:

– there must be consent from the person to whom the personal data relates,

– there is a statutory obligation to process the personal data,

–the personal data must be processed because there is a contract with the person to whom it relates,

– the personal data must be processed in order to protect the life of the data subject or another person, for example in connection with life-critical care and other situations where the data subject cannot give their consent,

–the processing of personal data is necessary in connection with the exercise of public authority or when performing a task of public interest regulated by law or similar, or

– the processing of personal data is necessary and outweighs the data subject’s interest in the protection of their personal data, a so-called balancing of interests.

With regard to the publication of personal data on social media, the legal basis in most cases involves either the existence of consent or a balancing of interests in which publishing the personal data is deemed more important than the individual’s interest in protecting their personal integrity.

Special caution regarding persons under the age of 13

Under the Act with Supplementary Provisions to the EU General Data Protection Regulation, the person with parental responsibility must give consent to the processing of personal data for persons under the age of 13 when personal data is processed in connection with our offering access to our own social media, such as discussion forums or member pages.

Monitor comments made on social media 

We have an obligation to monitor the comments made by others in our social media channels so that we can detect and remove personal data published about others without consent, or where publication is not more important than the individual’s interest in protecting their personal integrity. If we fail to remove personal data that must not be published, we may be liable for damages.

Inform about who is responsible

Under the Act on Responsibility for Electronic Notice Boards (the BBS Act), we must provide information about who is responsible for a given channel, such as a Facebook page. We must also inform users about how public the channel is and to what extent others can see what is posted there. An example might be: “Responsible for this page: RFSL. All content on the page is visible to everyone, but only page members may make posts. Membership must be approved by the page administrator.”

Remove posts that may be offensive

The BBS Act, like the GDPR, places an obligation on us to monitor our social media channels. We are also required to remove posts that may be offensive, contain incitement, incitement to hatred against a group, child pornography, illegal depictions of violence, or infringement of copyright. Failure to do so may result in the person responsible being sentenced to fines or imprisonment.

What constitutes offensive content must be assessed on a case-by-case basis. There is no clear definition of this in the law. Whether information is offensive within the meaning of the law also depends on the purpose of the publication. The Swedish Data Protection Authority’s website kränkt.se contains frequently asked questions and answers that can help in assessing whether a post should be removed or not.

Inform about so-called cookies

For websites, blogs, and other social media for which we are responsible for the technical platform, we must also comply with the Electronic Communications Act (LEK). This means we must inform users that we use so-called cookies — small text files saved on users’ computers. Users must also give their consent to our storing cookies on their computer. The information about cookies must include the cookie’s name, its purpose, and how long it is stored on the user’s computer.

2.3. Our Ways of Working

Work with a social media channel can be divided into an initial preparation phase and an active phase involving the ongoing management of the channel.

In the initial phase, we need to think through and decide what our goal and purpose is for the specific channel. We also need to appoint those responsible and produce the information that must be available about the channel, in accordance with the requirements set out in legislation. This information shall be published in the channel and must include:

– Who is legally and practically responsible for the channel. (The federation, a branch, a project, an activist group, etc. If it is a project, an activist group, or similar, the federation or branch must also be named.)

– What the purpose of the channel is.

– To what extent posts will be accessible to others.

– What may not be published.

– What will happen if the rules are breached.

In social media work, it is important to engage people. To do so, regular updates and a personal, accessible mode of expression are required. RFSL shall not have any abandoned channels. Channels that we are no longer actively working with shall be closed.

To make it easier to find our various posts and connect them to a context, it is important to use relevant hashtags such as #hbtqpol, #pride, or #hiv.

In order to maintain a safe environment and promote a high level of positive activity in our social media channels, we do not respond to obvious trolling.

To sustain user engagement, preserve the safe environment, and ensure compliance with applicable laws, we must monitor our social media channels. We work to detect and remove offensive personal data and other offensive content.

We are aware that personal integrity and anonymity are important, and in some cases vital, for many LGBTQ+ people, and we therefore always exercise the utmost caution in what we publish, so that individuals featured in a post cannot be identified unless they have given their consent. We also verify the suitability of a post with the individuals concerned.

The executive board shall adopt guidelines for how personal data shall be handled. These guidelines shall be followed by all those covered by the common rules.

No direct questions shall be left unanswered, but we shall avoid responding if we are not certain, in such cases it is better to ask to come back with an answer. All press enquiries shall be directed immediately to the appropriate person and shall not be handled via our social media channels.

2.4. Our Mode of Expression

RFSL’s social media channels shall, within the conditions of the respective channel, offer a safe online environment for LGBTQ+ people. No one should feel offended or questioned on the basis of who they are, and everyone’s right to self-identification shall be respected. This means that we use the pronoun(s) and name(s) that people state they use, and that we do not permit anyone to out another person.

In our social media, we use simple, accessible language, and we are clear about which channels and opinions are our private ones and which belong to RFSL.

Our posts on social media shall be grounded in RFSL’s values as expressed in our statutes and programme of principles. We are not afraid to take a stand and do not shy away from making even sharp criticism when it is warranted. However, we never take a party-political or religious stance. This does not, however, mean that we refrain from criticising parties, or political and religious representatives, for homophobic, transphobic, or racist views.