This Policy applies to all employees, doctors, consultants and / or vendors of Gleneagles Hospitals and any individuals (including trainees, interns, and contractors who are not employees but are contractually bound with the Company and carry out work or activities as representatives of the Company). It covers the use of social media by employees, doctors, consultants and / or vendors, for both business and personal reasons, regardless of whether the use occurs on Company’ premises, while traveling for business or otherwise, or while working from home.

1. What are the various types of social media? 

• Social media sites and services include (but are not limited to):
  • Popular social networks like X (formerly twitter) and Facebook.

  • Photographic social networks like Flickr and Instagram and IG Threads

  • Question and answer social networks like Yahoo Answers, Quora and Reddit 

  • Professional social networks like LinkedIn.

  • Feedback websites like Glassdoor, Mouthshut, Google Reviews etc

  • Content marketing sites like Out Brain, Medium.

What is the purpose of Company’s social media accounts?

The Company’s social media accounts are used for different purposes as mentioned hereinbelow. Employees, doctors, consultants and / or vendors who have been authorized (either by way of their employment contract or by way of explicit written authorisation or contractually) to use the Company’s social networking accounts may use them to:

• Respond to customer enquiries and requests for help;

• Promote brand awareness campaigns and services;

• Support new product launches and other initiatives; and
  Share insightful articles, video and other content relevant to Company’s business.

When can employees, doctors, consultants and / or vendors use their own personal social media account in relation to any activity, event, campaigns, publications or the like, made by the Company or in relation to the Company?

• Employees, doctors, consultants and / or vendors may use their own personal social media accounts for work related purposes as directed by their respective reporting heads, during regular hours. Such work-related purposes may include competitor research, to discover content to help them learn and develop in their role, or for any other purposes as may be communicated by their reporting managers, in the best interests of the Company.

• Personal accounts of the employees, doctors, consultants and / or vendors may be used to re-share posts made by the Company on its social media accounts, without editing the original post (in language, context or intent).

• The use of personal social media accounts for non-work purposes is restricted to non-work times, such as breaks and meal times.

• Employees, doctors, consultants and / or vendors should ensure that it is clear that the content mentioned in their personal social media account does not represent the Company’s views or opinions in any manner whatsoever.

Protect Information: Employees, doctors, consultants and / or vendors must not share or discuss confidential patient information or business data publicly online or with unauthorized persons. They should not publish, post, or release any patient details and/or any confidential information not intended for public dissemination. Employees, doctors, consultants and / or vendors approached by the media with queries regarding the Company’s patients or the Company, should direct these inquiries to the Group Corporate Communications team.

Be Transparent and Disclose Affiliations: Employees, doctors, consultants and / or vendors are required to disclose their employment or contractual relationship with the Company, if their roles involve speaking on or maintaining social media platforms on behalf of the Company. They should identify themselves as employees, doctors, consultants and / or vendors of the Company, and provide context to discussions to prevent misleading others into believing they are unaffiliated customers. Employees, doctors and consultants must be cautious not to appear as endorsing any vendor, product, or service on behalf of the Company.

Abide by the Law: Remember, there is no true anonymity on the internet. Anything shared online can be screenshot, shared, and traced back to the individual. Consequently, an employee's, doctor’s, consultant’s and / or vendor’s postings can be linked back to the Company, potentially affecting its image and reputation, and may expose the employee, doctor, consultants and / or vendor to legal liabilities and criminal prosecution. Employees, doctors, consultants and / or vendors must not post, share, or upload any content that is defamatory, obscene, can result in infringement of copyright, trademarks, patents, designs or any other intellectual property of any third party, discriminatory, libelous, insensitive, or simply rude.

Be Responsible: Employees, doctors, consultants and / or vendors must not comment on work-related matters on social media unless explicitly permitted or required by the Company. Employees, doctors, consultants and / or vendors must not register for social media accounts using their work email or use private and work accounts interchangeably. They should quickly admit to and correct any mistake made online. 

Furthermore, employees, doctors, consultants and / or vendors should post disclaimers to distinguish personal views from their official capacities, e.g., a disclaimer in their social media profile stating "The views expressed are my own and do not reflect the views of my employer/ the Company."

Be Nice, Have Fun, and Connect: If engaged in a conversation with someone abusive, provocative, or unreasonable, it is wise to disengage and exit the conversation as soon as possible. Prolonged participation in such engagements can lead to being drawn into controversial conversations and detract from the enjoyment of being online. A polite and responsible online community enhances learning and connectivity among people.

Follow the Approval process: In the event any employee, doctor, consultant and / or vendor wish to post any photos displaying the brand name and / or logo of the Company (which is not posted by the Company on its own social media platform or brand handle already) on their personal social media accounts, the employee, doctor, consultant and / or vendor shall follow the below mentioned approval process, to be duly permitted to perform such activities:

• The employee, doctor, consultant and / or vendor is required to raise a prior written request to the Group Corporate Communication team, at least 48 hours prior to the estimated time of posting the same.

• On the basis of the receipt of the request, the Group Corporate Communications team shall analyse the relevance and need for posting the same, in the best interests of the Company. In the event the post is considered to be in the interest of the Company, the Group Corporate Communications team shall provide its approval and only upon receipt of the approval in writing, the employee, doctor, consultant and / or vendor shall be permitted to post the photo on their respective personal social media accounts.

Don’t

• Employees, doctors, consultants and / or vendors shall not write or express anything on social media which may be defamatory to the Company or other employees, doctors, consultants and / or vendors. 

• Employees, doctors, consultants and / or vendors shall not publish rumors and/ or internal and/ or confidential information about the Company or related third parties on social media that can have a negative impact on the Company’s image and reputation. 

• Employees, doctors, consultants and / or vendors shall not use the Company’s logo/ identifier/ tradename/ trademark or nomenclature in the display picture or group name etc. 

• No employee, doctor, consultant or vendor should forward or discuss messages/ views without official confirmation or knowing authenticity or full fact and background of any matter against the Company, any individual or against the Government or any constitutional body.

• Employees, doctors, consultants and / or vendors should not canvass for any donation, lottery or third-party marketing / business promotional activities / affairs on any interest site or social media.

• Employees, doctors, consultants and / or vendors are prohibited from live streaming or posting any videos of any internal / external events of the Company in which they have participated or attended, whether in the premises of Gleneagles Hospitals or outside, where copyrighted music or videos are being played, except by the Group Corporate Communications Team. Failing to comply with the same will result in strict disciplinary and / or any other action that will be taken against such employees, doctors, consultants and / or vendors, as may be determined in the best interest of the Company. 

• Unauthorised usage of any Intellectual Property right (including trademarks, copyrights, patents, designs, etc.) which is otherwise registered / owned / licensed by a third party, will not be, in any manner whatsoever, permitted, either directly or indirectly by employees, doctors, consultants and / or vendors, wherein the unauthorized usage of which would, otherwise, amount to infringement or passing off, and might make the Company directly or indirectly liable for such actions. Any violation of the same shall result in strict disciplinary and / or any other action that will be taken against such employees, doctors, consultants and / or vendors, as may be determined in the best interest of the Company.

•      Employees, doctors, consultants and / or vendors must not use the Company’s logo, trademarks, or other branded materials of the Company, for personal social media posts, including all holiday and festival greetings, or other personal wishes, unless a template for the same is being provided by the Company. This helps maintain a clear separation between Company’s official communications and individual employee’s, doctor’s, consultant’s and / or vendor’s posts. 
•      Taking and sharing photos, videos, or reels within the premises of the Hospital units of the Company for personal social media use, is strictly prohibited. This Policy helps protect patient’s and Company’s privacy and confidential information, to maintain a professional environment, and to prevent the inadvertent disclosure of unwanted, sensitive, personal or confidential information. Employees, doctors, consultants and / or vendors should refrain from capturing / circulating / posting on any form of media, that is taken on Company’s or its Hospital units’ premises, using their personal social media accounts.

Reporting Inappropriate Activity:

• Employees, doctors, consultants and / or vendors shall report any inappropriate or harmful content related to the Company on social media platforms to the designated supervisor, the Group Corporate Communications department and HR department.

• Ignorance of the Policy or its guidelines also cannot be allowed as an excuse to breach this policy. 

• If any employee, doctor, consultant or vendor notices any violation of this Policy, posting something concerning on social media that does not align with the Company’s core values, such as exhibiting signs of aggression or threatening others he/ she should bring this to the notice of the Company.

• Any employee, doctor, consultant and / or vendor who feel that they have been harassed or bullied or are offended by the material posted or uploaded by another employee, doctor, consultant and / or vendor onto a social media, must inform the Group Corporate Communications department and HR department immediately for investigation and taking further action, if appropriate.

How does the Company enforce the Policy?

• Company IT and internet resources – including computers, smart phones and internet connections are provided for legitimate business use.

• The Company reserves the right to monitor how social networks are used and accessed through these resources. Any such examinations or monitoring will only be carried out by authorized employees.

• All data relating to social networks written, sent or received through the Company’s computer system is part of official company records.

• The Company may be legally compelled to show that information to the police, law enforcement agencies or other parties.

• The Company shall conduct regular training sessions for the employees, doctors, consultants and / or vendors on the applicability of this Social Media Policy, the dos and don’ts, and consequences in the event of breach of this Policy. 

What is the disciplinary or other actions that can be taken by the Company for breaching the Policy?

Knowingly breaching the policy is a serious matter. Employees, doctors, consultants and / or vendors may be subject to strict disciplinary and / or any other action that will be taken in the best interest of the Company, as solely determined by the Company, including termination of employment or contract. Where deemed appropriate, the Company will involve the police or other law enforcement agencies. 

Disciplinary and / or other Consequences:

• The Company reserves the right to monitor, prohibit, restrict, block, suspend, terminate, delete, or discontinue the employee’s, doctor’s, consultant’s and / or vendor’s access to social media, at any time (when the social media belongs to the Company or when the assets/infrastructure of the Company are being utilized for accessing social media), without notice and for any reason and in its sole discretion. 

• The Company may disclose the communications and activities of the employees, doctors, consultants and / or vendors in response to lawful requests by governmental authorities, judicial orders, warrants, or for the protection of the Company’s rights.

• Disciplinary action and / or any other action as may be determined by the Company, in the best interest of the Company, shall be taken against the employees, doctors, consultants and / or vendors, including termination of employment or contract, if this Policy is not followed. Posting rumors, internal and confidential information can lead to legal action to be taken against the employee, doctor, consultant and / or vendor. Examples of non-conformity with this Policy include but are not limited to:

1. Disregarding job responsibilities and deadlines to use social media at work.

2. Disclosing confidential information through personal or corporate accounts.

3. Directing offensive comments towards other members of the online community.

4. Passing off personal views as the Company’s views.

5. Making any statement on behalf of or attributable to the Company on platform without obtaining written consent therefor.

6. Posting rumors, any disparaging statements or any deliberate statements with the aim of negatively impacting the goodwill and/or reputation of the Company.

What is the general advice on using social media?

Indemnity:

Employees, doctors, consultants and / or vendors shall defend, indemnify, and hold the Company and its corporate affiliates and their respective officers, directors, employees, contractors, agents, successors and assigns harmless from and against, and shall promptly reimburse them for, any and all losses, claims, damages, settlements, costs, and liabilities of any nature whatsoever (including reasonable attorneys' fees) to which any of them may become subject arising out of, based upon, as a result of, or in any way connected with, such employees, doctors, consultants and / or vendors posting of any content to a social media site.

Know the social network

• Employees, doctors, consultants and / or vendors should spend time becoming familiar with the social network before contributing. It is important to read this Policy and any FAQs and understand what is and is not acceptable on a network before posting messages or updates.

• If unsure, do not post any material. Employees, doctors, consultants and / or vendors should err on the side of caution when posting to social networks. Once the post is online, it is already on the record and becomes public and searchable. Hence, what is written and posted is ultimately the employee’s, doctor’s, consultant’s and / or vendor’s responsibility.

• Look out for security threats - Employees, doctors, consultants and / or vendors should be on guard for phishing attempts as social networks are also used to distribute spam and malware.

Handle complex queries via other channels.

• Social networks are not a good place to resolve complicated enquiries and patients’ issues. Once a patient has made contact, employees, doctors and / or consultants should handle further communications via the most appropriate channel, e.g. email or telephone.

• Don’t escalate things-It’s easy to post a quick response to a contentious status update and then regret it. Employees, doctors, and / or consultants should always take the time to think before responding and hold back if there is any doubt at all.

What is the disciplinary action for breaching the guideline? 

• Any content put up on an employee’s, doctor’s, consultant’s and / or vendor’s personal social media platforms may be traced and linked back to the Company. Employees, doctors, consultants and / or vendors should therefore exercise due caution when using social media for personal or social purposes to avoid bringing disrepute to the Company. 

• Employees, doctors, consultants and / or vendors who breach the guideline or the Company’s Social Media Policy may be subject to strict disciplinary and / or any other action as may be determined by the Company in the best interest of the Company, including termination of employment or contract, if their actions are deemed to have negatively affected the Company’s image and reputation and/or caused financial loss to the Company.

The Company reserves the right to amend/withdraw the Policy at any time without assigning any reason whatsoever. The utility and interpretation of the Policy will be at the sole discretion of the Management.