Author Name:   abhishekpandey

Internet laws: Social media can well be termed as a tool of divulgence and convergence of information. But such tool is more or less used by individuals and few organizations....

Social Media Governance In India

Social media can well be termed as a tool of divulgence and convergence of information. But such tool is more or less used by individuals and few organizations. The uses of such platform by the governmental agency to connect to the masses and create synergies between them have been minimal. However, agencies have started opting for policies to effectively use these platforms to create scope of engagement with public and to engage all the stakeholders to make policies citizen centric. In India, practice of using social media platforms by the governmental agencies have gained pace. In Indian context, Ministry of External Affairs excelled in using these platforms when its Public Diplomacy (PD) division launched its Twitter account on July 10, 2010. The launch of such account heralded a new history of government-stakeholder communications in India. At present, social media sites have accounts of traffic controls, police departments, municipal corporations and health institutions etc. Keeping in view the need of a guideline to encourage government institutions to use these platforms as a channel of communication, Department of Information Technology, Ministry of Communications and Information Technology, Government of India came up with a ‘Framework and Guidelines for Use of Social Media for Governmental Organisations’ in September, 2011. The question which becomes imperative to address in regard to such guideline is whether creation of a guideline by itself is sufficient enough to celebrate or there exists some concerns to be noted in this regard.

I. Social Media Governance: Meaning, Need and Core Values
Governance can be termed to be the process whereby societies and institutions make their important decisions, determine who they will involve in making those decisions and how they render account. Typically, a governance process will rest on a governance system or framework—that is, the agreements, procedures, conventions and policies that establish who has power, how decisions are taken and communicated, and how accountability is rendered. Social media governance can be termed to be a procedure wherein to ensure good governance social media is used by the governmental agencies. The draft Indian framework points out that though at personal level, the uptake and usage of social media is gaining rapid popularity, use and utility of such media for official purpose remains ambiguous. Many apprehensions remain including, but not limited to issues related to authorisation to speak on behalf of department/agency, technologies and platform to use to communicate, scope of engagement, creating synergies between different channels of communication, compliance with existing legislations etc. Therefore, In order to encourage and enable government agencies to make use of this dynamic medium of interaction, a basic framework and guidelines for use of Social Media by government agencies in India has been formulated. These guidelines will enable the various agencies to create and implement their own strategy for the use of social media. The document will help them to make an informed choice about the objective, platforms, resources, etc. to meet the requirement of interaction with their varied stakeholders.

The Guidelines have been developed for all e‐Governance projects currently under National e‐Governance Plan, whether being implemented at Central or State level. In addition, it will be applicable to all new e‐Governance Projects being developed by any Department or Line Ministry of Central Government. All other government agencies including Public Sector Undertakings may also find it useful while conceptualising their own projects. It is expected that the utility of these guidelines will transcend NeGP and will be used by all departments

It further observes that ‘given its (social media’s) characteristics to potentially give “voice to all”, immediate outreach and literally 24X7 engagement, social media offers a unique opportunity to governments to engage with all their stakeholders especially citizens in real time to make policy making citizen centric. Many governments across the world as well many government agencies in India are using various social media platforms to reach out to their citizens, businesses and experts to seek inputs into policy making, get feedback on service delivery, creating community based programmes etc.

The framework lays down that social media is more interactive, enables one‐to‐one conversation and demands immediacy in responses than the traditional media. Also, on such platforms the perception of official and personal roles and boundaries is often blurred. Therefore, while using social media especially for official purposes, the following values may be kept in mind to smoothen the interaction:
1. Identity: It requires that one should always identify clearly who he is, what is his role in the department and publish in the first person. Disclaimer may be used when appropriate.
2. Authority: It suggests not commenting and responding unless authorized to do so especially in the matters that are sub‐judice, draft legislations or relating to other individuals.
3. Relevance: It advices to comment on issues relevant to one’s area and make relevant and pertinent comments. This will make conversation productive and help take it to its logical conclusion.
4. Professionalism: It asks to be polite, be discrete and be respectful to all and do not make personal comments for or against any individuals or agencies. Also, professional discussions should not be politicized.
5. Openness: It suggests being open to comments – whether positive or negative. It is not necessary to respond to each and every comment
6. Compliance: It requires complying with relevant rules and regulations and suggests not infringing upon IPR, copyright of others.
7. Privacy: It advices not to reveal personal information about other individuals as well as not to publish one’s own private and personal details unless the person wishes for them to be made public to be used by others.

It has been noted that as the influence of traditional media sources like television networks and newspapers will decline, social media will become a critical part of government public relations and outreach. In an environment of rapidly changing global issues, an increasingly fractionated media sector, and people more and more defined by unique combinations of niche interests, the government sorely will need enhanced public relations that will involve bi-directional multimedia engagement with specific niches of public interest. Since every citizen has the potential to be a collector, an analyst, a reporter, and a publisher and so does every government employee, therefore engaging, trusted personalities employed as brand ambassadors over social media will complement -- not replace -- traditional public affairs and government outreach.

II. Social Media Practices
In USA, several government agencies are taking advantage of social media tools for recruiting and talent management, as well as improving job performance. For example, the CIA leverages Facebook as a method of attracting college students to apply for internships or jobs. The Environmental Protection Agency created a Facebook network for employees to achieve better talent management as a way to share knowledge, build collaboration and improve employee engagement. Other agencies are using public social networking Web sites as models for their own sites. NASA’s CoLab program involved building its own collaborative workspace site to develop and support both online and offline groups and communities of practice. This allows its own internal groups to form a collaboration network and link to non-NASA groups of like-minded, technologically knowledgeable people and tap into the expertise of non-NASA scientists and engineers. Using social networking tools is not limited to U.S. federal agencies. State, county and municipal governments are also getting into the act of leveraging these tools to carry out important functions. During summer 2009, adjoining counties in Texas have started their own Facebook and Twitter sites to make it easier for the public to access important information such as that provided by the counties’ emergency management offices. While many local government agencies including Mayor’s offices of many cities in United States use social media for community building and even recruitment, most state and federal agencies use social media for either seeking expert opinion or creating/influencing public opinion. Many agencies at federal level are also using this platform to gauge public reactions on upcoming/proposed policy measures. Given below are a few examples from across the world. In addition to established platforms created by private organisations, US government has also created its own platforms. A new social network Web site called GovLoop.com was created a year ago within the US Department of Homeland Security to share experiences and best practices. More than 14,000 people have joined, creating nearly 500 sub‐communities and over 1,000 discussion forums.

The Human Capital Institutes report point out that:
1. Sixty-six (66) percent of government workplaces use some type of SN tool and sixty-five (65) percent of those are using more than one tool.
2. These tools are used for a variety of internal and external-facing goals with employee training and public relations the work functions SN tools are most frequently used for.
3. Communities of practice and blogs are the most frequently used SN functions.
4. LinkedIn, Facebook and Twitter are the most frequently used SN Web sites highlighting the value that many organizations find in leveraging already existing tools for their own purposes.
5. The most used SN functions build capabilities in collaboration and knowledge sharing.
6. The most used SN Web sites also aid collaboration and the building of professional networks.
7. Overall, SN tools are perceived as most effective at handling information and communication in internal processes and goals such as management functions. Public communications and recruiting functions are in the mid-range of effectiveness, while the use of SN tools for managing work trails behind.
8. Federal agencies (defense and non-defense) lead the way in using SN tools for project planning (an internal process) while state government agencies lag.
9. State government agencies are significantly less likely to use SN tools than either county/municipal or federal agencies possibly a result variation among states in having the budget and expertise to implement social networking.

It is because of these characteristics of social media that it has been predicted that less than 30 per cent of large organisations will block employee access to social media sites by 2014, compared with 50 per cent in 2010. As per a report, the number of organisations blocking access to all social media is dropping by around 10 per cent a year

With a mandate to include production of print and audio-visual materials to help Indian embassies in projecting the country’s diverse facets more effectively, the Public Diplomacy (PD) division of the Ministry of External Affairs (MEA) launched its Twitter account with the user ID “Indian diplomacy” — http://twitter.com/Indiandiplomacy  on July 10, 2010. The account was a big hit with its launch and as of now have 1,955 tweets and 27,814 followers. The platform is regularly used by Indian diplomats and the Prime Minister's Office (PMO) for routinely tweeting on foreign policy matters. On account of such success, the division started using other platforms like Facebook, Youtube, Flickr and Issuu. The Facebook page had been a bit slow to pick up in the first few months, but has now over 50,567 likes. More importantly, over 50 Indian high commissions, embassies and consulates have now opened their own pages on Facebook and others are waiting in the wings. Recently, the tweets of the division were appreciated for the evacuation of Indian nationals from Libya during the NATO led war.

At present there are several agencies which have actively marked their presence on social media websites, including, Delhi Traffic Police, National Institutes of Health and Special Police Unit for Women & Children, Delhi Police etc. However it has to be noted that we are two steps behind the western world as they are not actively using these social media websites but are also using other web 2.0 applications for better governance. In west individuals and governmental agencies have collaborated to create web 2.0 applications for better governance purposes.

III. Social Media Framework and Guidelines for Government Organisations in India
In September, 2011 the draft framework and guidelines for use of social media for government organizations released. More recently, J. Satyanarayana, Secretary, Department of Electronics and IT recently observed that ‘keeping in mind the growing demand, the department will soon finalise the guidelines for all State and Central government departments wanting to use social medium to reach and get feedback from public.’ He further observed that social media is supposed to have a good reach and people are used to it. So the government created draft frame work for using the social media by various departments will be published soon.

The released draft framework comprises of the following 6 elements:
i. Objective: Why an agency needs to use social media
ii. Platform: Which platform’s to use for interaction
iii. Governance: What are rules of engagement
iv. Communication Strategy: How to interact
v. Pilot: How to create and sustain a community
vi. Engagement Analysis: Who is talking about what, where and what are the main points of conversations
vii. Institutionalisation: How to embed social media in organisation structure

(i) Objective:
The draft framework mentions that the purpose behind use of social media is not only to disseminate information but also to undertake public engagement for a meaningful public participation for formulation of public policy. It lays down that social media can be used for :
a. Seeking feedback from citizens
b. Re‐pronouncement of Public Policy
c. Issue based as well as Generic interaction
d. Brand Building or Public Relations
e. Generating Awareness and education on National Action Plans and implementation Strategies

(ii) Choosing Platform
The guideline directs that once the objectives have been defined the next step of identifying platforms in which engagement shall be undertaken should be done. It mentions that the government departments and agencies can engage social media in any of the following manner:
a. By making use of any of the existing external platforms, or
b. By creating their own communication platforms
c. The choice of the platform – whether owned or externally leveraged should be made based on the following factors:
d. Duration of engagement ‐ whether the engagement sought is to be an ongoing activity or created for a specific time‐bound purpose
e. Type of Consultation – whether the consultation is open to public or confined to a particular group of stakeholders e.g. experts
f. Scope of Engagement – whether the consultation requires daily, weekly, bi‐weekly or even hourly interaction
g. Existing Laws – whether existing laws permit use of such platforms and the requirement under such laws regarding data protection, security, privacy, archiving etc.

(iii) Governance Structure
Owing to the viral characteristic and demand for gratification over social media the official page of departments must reflect the official position and shall also incorporate some measures of control. The guideline suggest for a governance structure comprising of account governance, response and responsiveness, resource governance, content governance and data and security information governance.

(iv) Communication Strategies
Following communication strategies have been mentioned in the draft:
1. Social media can only be used by the Government to communicate existing Government information and propagate official policy to the public.
2. While the social media tools allow everyone to become a creator, for the official account, content will have to be specified and tailored to the site on which it is being published.
3. Great care must be taken to avoid propagation of unverified facts and frivolous misleading rumours which tend to circulate often through miscreants on social media platforms.
4. It must be reiterated here that social media should only be one of the components of the overall citizen engagement strategy and government departments must desist from using only social media to communicate with their stakeholders.
5. Initially, the departments may just aim to post information regularly. For example, if it is a Face Book Page, postings may be done at least a couple of times a week and on Twitter slightly more frequently.
6. Ideally, none of the sites should be left more than a week or two without new content.

(v) Creating Pilot
The draft framework lays down that since social media are relatively new forms of communication, it is always better to test efficiency and efficacy of such an initiative with a pilot project. Some of principles of creating such a pilot are mentioned as below:
1. Focused Objective setting: Initiate interaction for a limited objective or limited to one topic
2. Begin Small: It is always better to start small and it is advisable to begin with one or two platforms.
3. Multiplicity of access: The chosen platform should typically permit inputs from or linkages through multiple access devices. This will ensure wider participation.
4. Content Management: It is not enough just register presence on a variety of platforms. As we are all aware, government websites are perhaps the least visited websites. The reasons for this are manifold including but not limited to the relevance, updation and presentation of content.
5. Community Creation: On any social media platform, creation of a community is essential to generate buzz and sustain interaction.

(vi) Engagement Analysis
The framework emphasizes that social media monitoring must be an integral part of any social media strategy. Social media data is different from other data or information because organisations have no control over its creation or dissemination on the Web and in order to understand and analyse the data a structure has to be imposed externally on it. It suggest to use Social Network Analysis software to be used in discovering conversations about project and organisations which can be used to proactively engage with stakeholders.

(vii) Institutionalise Social Media
The framework observes that the final step in ensuring that the pilot is scaled and integrated is to link to existing administrative and communication structure. It provides for an indicative list as follows:
1. Rules may be established that all policy announcements will be undertaken simultaneously on traditional as well as social media;
2. All important occasions as far as possible may be broadcasted using social media;
3. All documents seeking public opinion must be posted on social media sites;
4. All updates from the website would automatically be updated on social media sites and;
5. All traditional communications will publicise the social media presence.

IV. Conclusion
It is a well known fact that the social media is evolving at ‘mouse click’ speed. The dynamism of the social media calls for all the governance guidelines to be regularly reviewed and updated. It is required that the agencies make sure that they define the frequency of updates and the process for those updates. Such updating will certainly ensure that the governance model does not become outdated. It is also required that the employees be given training and education on responding to queries.

It has been a general observance that once an agency marks its presence on social media, they are enthusiastic in exchanging tweets and comments. However over a period of time these pages on social media transform into a static page. So, it is required that not only accounts are set up but also they are actively managed and administered. Another problem with such account relates to transitioning of such accounts to a new person where the old employee leaves the agency.

No doubt, it is good to receive traffic updates, crime alerts and policy information but governmental agencies should not forget that the purpose of being available on social media is not merely information dissemination. The purpose to be on social media is to interact and to implement those suggestions which come out of community interaction. Such interaction will certainly ensure transparency among government institutions and will sub serve the masses. In the near future social media has much to contribute to the key goals of better, simpler, joined-up and networked government.
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 # Framework and Guidelines for Use of Social Media for Governmental Organizations, Department of Information Technology, Ministry of Communications and Information Technology, Government of India at 4.
# Id. at 6.
# Id. at 10.
# See generally, Mark Drapeau, “Government 2.0: How Social Media Could Transform Gov PR”, available at: www.pbs.org/mediashift/2009/01/government-20-how-social-media-could-transform-gov-pr005.html (Visited on March 23, 2013).
# Human Capital Institute and Saba, Report on Social Networking in Government: Opportunities & Challenges (2010) at 4.
# Supra note 1 at 31.
# Ibid.
# Supra note 5 at 2.
# “By 2014, fewer companies will block social media: Gartner”, available at: http://www.thehindubusinessline.com/industry-and-economy/info-tech/article2967342.ece (Visited on March 7, 2013).
# PD is the framework of activities by which a government seeks to influence public attitudes in a manner that they become supportive of foreign policy objectives and national interests.
# “Tharoor gone, MEA debuts on Twitter: public diplomacy”, available at: http://www.indianexpress.com/news/tharoor-gone-mea-debuts-on-twitter-public/644664/ (Visited on April 05, 2013).
# “IndianDiplomacy posts on Twitter”, available at: http://www.publicdiplomacyblog.com/2012/04/indiandiplomacy-posts-on-twitter.html (Visited on April 05, 2013).
# Ibid.
# For e.g., E-petitions is an initiative launched by the office of the Prime Minister in the UK. It allows people to submit petitions directly to the PM, and to see and sign petitions created by other people; Intellipedia is a wiki-based platform which enables the direct collaborative drafting of intelligence reports by analysts from different intelligence agencies, with little or no hierarchical filtering; Peer-to-Patent is an initiative launched by the New York Law School and endorsed by the US Patent Office. It aims to improve the process for reviewing patents, which is made slower and less effective by the high number of patents to be processed and the technical knowledge required. European Commission’s Institute for Prospective Technological Studies, Report on Web 2.0 in Government: Why and How? (2008).

# See “Guidelines for govt. departments using networking sites soon”, available at: http://www.thehindu.com/sci-tech/internet/article3284280.ece?css=print (Visited on April 10, 2013).
# Clause 5.1.1.
# Clause 5.1.2.
# Clause 5.1.3.1, deals with the account governance and suggests that since a social media account establishes an organisation’s online identity, wherever possible, the same name for the different social networking accounts may be adopted to ensure ease of search on the internet. A proper record of login ids and password must be maintained. It is also important to define whether the engagement may be undertaken through official accounts only or the officials may be permitted to use personal accounts also for posting official responses.
# Clause 5.1.3.2, deals with response and responsiveness and observes that since the major attraction of social media is the spontaneity and immediacy of response and feedback and those visiting the site would expect the some kind of response within a pre‐defined time limit. As far as possible, it is important to state upfront the scope of response – given/not given, type of response – official/unofficial, response time – 1 day/1 week etc. so that expectations are set correctly.
# Clause 5.1.3.3 deals with resource governance and mentions that using social media is a resource intensive exercise, hence, it is important to ensure that resources and their responsibilities are clearly marked out very early. It also defines various roles and responsibilities of the team responsible for creating, managing and responding social media platforms
# Clause 5.1.3.4 deals with content governance and observes that content creation & social media profiles overlap, therefore sharing consistent content on all social media platforms should form the bedrock of content policy. While the social media tools allow everyone to become a creator, for the official account, content will have to be specified and tailored to the site on which it is being published. It urges for creation of a moderation policy to be published if the platform permits others to add their own content. It also requires for record management.
# Clause 5.1.3.6 lays down that the government’s communication to citizens via social media should follow the same data retention policy as its communication through other electronic and non‐electronic channels. Data portability compliance varies from one social media platform to another. Hence, privileged access may be mandated by the Government along the same lines “take down notices” and “information requests” currently being sent to social media and other platforms for intellectual property rights infringement and other offences.
# Clause 5.1.3.4.
# Clause 5.1.3.5.
# Clause 5.1.3.6.
# Clause 5.1.3.7.

The  author can be reached at: abhishekk@legalserviceindia.com

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