Overview

Social media can be used by ministers to connect with constituents and communicate important government information. In order to be protected from any potential risks in their use of social media, ministers and their staff should be aware of the OPS Social Media Guidelines and other guiding legislation (for example, the Member’s Integrity Act (MIA), principles and policies that would guide their use.

Bill 254, Protecting Ontario Elections Act, 2021 amended the MIA to provide legislative guidelines on a minister’s (and MPPs’) use of social media. It outlines that MPPs can publish any content they think would be of interest to their followers. This could include content related to the member’s portfolio, government policies, programs and initiatives or partisan content.

However, content that is posted by a member of the minister’s office on behalf of the minister, must be consistent with the requirements of the Public Service of Ontario Act, 2006 and its regulations governing the permissible activities of public servants.

Guidelines for a minister’s personal account

Minister social media accounts are considered personal accounts, separate from the official Government of Ontario ministry accounts. They can only be created and maintained by the minister and their designate.

Minister social media accounts can be managed by the minister or minister’s office staff. However, OPS ministry staff should not be tasked with account set-up or account management. In addition, OPS ministry employees or resources (devices, content and creative, etc.) cannot be used to solely support a minister’s personal account, as this would unfairly benefit the personal profile of the minister.

As a reminder, only official ministry social media channels can:

  • indicate that it is an official government account
  • include the official Government of Ontario website and logo in the bio

Customer service

When dealing with an inquiry from the public that can be better addressed by a ministry or government body, you should refer the individual directly for assistance.

Alternatively, if the minister’s office would like to send the inquiry to the appropriate ministry or government body, they should:

  • obtain consent of the individual sending the inquiry
  • remove all unnecessary personal information from the inquiry when sharing with the inquiry (for example, a profile picture, credit card information)

Best practices for appropriate use

Appropriate social media use is based on specific circumstances.

Here are some examples that may help guide the use of a minister account.

Sharing job-related/ministry content

Appropriate use

Examples of use that may be appropriate include:

  • promoting the work of the ministry
  • retweeting ministry content and shareables about a new initiative
  • sharing appropriate stakeholder or third-party content
  • removing personal information from a question received on social media before sharing it via government channels

Inappropriate use

Examples of use that are inappropriate, because they go against a policy or principle, include:

  • expecting Ontario Public Service ministry staff to log into the account and respond to questions on the minister’s behalf
  • sharing an individual’s personal information through a government channel without their consent
  • using photos of Ontario Public Service staff in published content without proper consent

Talking about the workplace

Appropriate use

Examples of use that may be appropriate include:

  • posting photos or a message with highlights from a conference or event with proper permissions and approvals
  • sharing a positive news story about a ministry initiative

Inappropriate use

Examples of use that are inappropriate, because they go against a policy or principle, include:

  • publishing personal or private information about a constituent member
  • providing inaccurate or untrue statements

Sharing personal content

Appropriate use

Examples of use that may be appropriate include:

  • discussing a personal hobby or activity not related to work
  • sharing family anecdotes and photos with proper permissions and approvals
  • engaging with audiences in a professional or personal tone

Inappropriate use

Examples of use that are inappropriate, because they go against a policy or principle, include:

  • discussing a business opportunity to benefit a friend or family member
  • sharing or tagging a photo with unprofessional or inappropriate content
  • sharing copyrighted content without proper attribution

Sharing, tagging and liking

A minister’s social media account can share, like or engage with content posted on an official ministry account. However, an official ministry account may not publish, share, like or engage with partisan content or content posted on a minister’s account, where partisan content could be published.

For this reason, official ministry accounts should also refrain from tagging the account of the minister. This separation helps the public recognize official government communications and ensure ongoing trust in a non-partisan public service.

Content and creative

Content published on official ministry social media accounts can be posted organically, at the same time, or after it has been posted, on the minister’s social media accounts. This includes videos, photos and shareables.

Alternatively, content published on an official ministry social media accounts can be shared or retweeted by the minister’s social media accounts.

Content provided to a minister or minister’s office can be used as the minister sees fit. This includes:

  • posting the content as-is through their own accounts
  • using the creative assets to create and share their own posts through their accounts
  • sharing the ministry post (for example, retweeting)

MPP kits and MPP support

MPP kits that may include a news release, key messages, social media shareables and content that will be posted on the official ministry channels, as well as questions and answers, can be provided to the minister or minister’s office. A minister’s social media accounts can only share/retweet ministry social media posts or publish the same content at the same time.

Where an MPP is supporting a minister or acting on that minister’s behalf, ministry staff can provide the same support as they would with their own minister.

Posting minister photos or videos

Photos of a minister may only be posted to official ministry government social media accounts when the individual is working in his or her official capacity (for example, giving an official speech or making an official announcement).

However, the official ministry accounts should not tag the minister’s personal account.

Social media livestreaming and video support can be provided for the minister if they are working in their official capacity and the content is posted to an official ministry account (for example, the Premier of Ontario YouTube channel).

Considerations for minister’s office staff

Although minister’s office staff may have their own personal social media accounts, they may also manage and support minister social media accounts.

However, similar to OPS ministry staff, minister’s office staff are required to follow the PSOA and the Oath of Office in all matters, including when using social media.

Unlike other government employees, the personal social media accounts of the minister and minister’s Office staff may be more heavily monitored by the media. There is an increased chance for negative exposure if contentious or conflicting information is posted.

Please refer to the personal social media use section for guidelines regarding publishing and sharing content.

Risk

There is always a risk (for example, reputational damage to a person or employer) if you are sharing, posting, liking or interacting over social media.

Using a disclaimer like, “opinions are my own,” can help clarify that the account does not speak on behalf of the government, but it will not remove your obligations and responsibilities.

Just like all OPS staff, political staff who do not follow the legislation, principles or policies may be subject to discipline — up to and including dismissal.

Participating in political activity

Under the Public Service of Ontario Act (PSOA), a public servant who works in a minister’s office is entitled to engage in political activity.

However, minister’s office staff should not engage in political activity on social media during working hours and should not use government resources, equipment or supplies to support political activity.

The Integrity Commissioner, as their Ethics Executive, can provide additional direction on their obligations.

Collecting personal information, privacy and permissions

In regard to work-related activities, it’s important that you do not collect, post or share private or personal information about others without proper permissions and approvals.

For photos or videos of individuals, proper permissions and approvals could include:

  • consent forms
  • posting a notice of collection at a work-related event
  • verbal "OK" (understanding that this approval could be revoked at any time)

If you are unsure about what permissions are required or whether something is deemed private/personal, please speak to Premier’s Office Communications or refer to the Freedom of Information and Protection of Privacy Act.

Example scenarios

The following scenarios demonstrate how to apply the social media guidelines. However, the potential risks and things to consider are not exhaustive and staff are always encouraged to speak to their Communications Branch if they are unsure how to proceed.

Scenario 1

A minister is very proud of the work being done with their ministry and would like to promote it through their social media channels as the minister. They ask the ministry communications branch to help create sharables that will be used on their own minister social media channels.

Potential risks and things to consider:

  • Is the content partisan?
  • Is the created content being used solely on the minister’s account?
  • Is the content being shared or posted at the same time with an official ministry account?
  • Is the created content appropriate for the official ministry channel and contain the appropriate logo’s and identifiers?

Recommendation

Before making a decision, the ministry and minister/minister’s office should consider the risks.

If the content is not being used on an official ministry channel and/or the minister does not plan to post the content in parallel to the official account, the ministry should not be creating the sharables.

Read more about the legislation, principles and policies for social media use.

Alternative solution

The ministry could develop relevant content related to the request that would be of interest to their audience and in line with government messaging. The minister/minister’s office could then retweet/share the content to their accounts directly from the ministry account or post the content in parallel.

Scenario 2

The minister is proud of the work they do in their community as a Member of Provincial Parliament (MPP). The MPP would like to promote the work being done and promote a fund-raising activity. They ask their ministry to share a post in which the minister is out promoting the good work and to promote their activity.

Potential risks and things to consider:

  • Is this content partisan or non-partisan?
  • Does this content support government directives?
  • Are the photos or posts of a minister working in their official ministerial capacity?

Recommendation

Before making the decision, the ministry and minister/minister’s office should consider the risks.

Where the minister is not acting in their official ministerial capacity (for example, campaigning for an election), the ministry should not share the post.

Based on this scenario, and because the minister is not acting in their official ministerial capacity, the ministry should not assist or share the post. This would be considered partisan and does not support government directives.

As a reminder, photos or posts of a minister should only be shared to official government social media accounts when the individual is working in their official capacity (for example, giving an official speech or making an official announcement).

Read more about the legislation, principles and policies for social media use.

Alternative solution

The minister or minister’s office staff could ask community stakeholders, fellow MPPs and supporters to share their content to boost visibility.

Scenario 3

The minister will be making an announcement on an upcoming initiative. Part of the strategy is to live-stream the event. The minister/minister’s office staff asks the ministry to set up and broadcast the event from the ministry’s official social media channels.

Potential risks and things to consider:

  • What is the context of the event and does it relate to the work of the ministry?
  • Would the audience on the official ministry account find the event content engaging?
  • Who is responsible for organizing and managing the livestream?
  • What social media platforms will be used?
  • Is the format AODA-compliant?
  • Will there be a simultaneous stream with French closed captioning and/or live French interpretation?
  • What additional assets, if any, will be required for the event (for example, a banner or posters)?

Recommendation

Before making a decision, the ministry should consider the risks.

Social media livestreaming and video support can be provided for the minister if:

  • they are working in their official capacity
  • the content is posted to an official ministry account

If the purpose of the video or livestream is to only broadcast on the minister’s social media channel and/or if the content is political in nature, the ministry should not assist.

Read more about the legislation, principles and policies for social media use.

Scenario 4

A ministry communications branch has developed content for an upcoming announcement. The content includes a news release, key messages, social media shareables/content, and question and answers. They have shared the content with the minister/minister’s office as part of an MPP kit.

The minister and/or minister’s office staff asks the ministry to provide additional social media posts and shareables to be considered for the announcement to ensure they have a lot to share.

Potential risks and things to consider:

  • Is all of the social media content being used on official ministry social media channels?
  • Will the minister’s office be altering the social media shareables/content in any way?
  • Is the minister or minister’s office account planning to share/retweet the official ministries content or post organically/in parallel on their own accounts?

Recommendation

Before making the decision, the ministry, minister and/or minister’s office staff should consider the risks.

Additional options could be created if they are also being published on the official ministry channel.

However, if the additional content is not being used on an official ministry channel, it should not be distributed for use on a minister account.

Read more about the legislation, principles and policies for social media use.

Alternative solution

The minister or minister’s office staff could ask community stakeholders, fellow MPPs and supporters to share their content to boost visibility.