UPMC Social Media Policy

This policy regulates the use by UPMC Italy (hereinafter "UPMCI" or "Company") of the social media channels administered by, and attributable to UPMCI, namely:

UPMC Italy
UPMC Salvator Mundi International Hospital

Purpose

UPMCI uses social media to inform, communicate, promote customer feedback and encourage participation, discussion and open dialogue with users (e.g,, patients or potential patients, health care providers, candidates, trade associations) and other public and private entities dealing with health and wellbeing and wishing to interact, even only on a preliminary basis, with the Company. UPMCI uses social media to inform and facilitate access to its services, pursuing institutional and general interest purposes. However, the content disseminated by the Company through its social media does not replace institutional publicity and transparency obligations.

This policy regulates the users' behaviors with regard to using and sharing content (images, texts, audio files, videos or a combination of the latter, on social media attributable to UPMCI, and indicates content and methods of interaction and virtual dialogue with the Company.

Furthermore, this policy regulates the behavior of staff responsible for managing accounts and social media pages officially administered by, and attributable to UPMCI.

Social network platforms

At the time of publication of this policy, UPMCI is present on the following digital platforms: Facebook, LinkedIn, YouTube. These platforms have specific technical requirements and usage policies for the various social networks, in addition to the rules described in this policy. These rules shall also apply should the Company decide to activate additional social networks.

Facebook pages

The UPMCI Facebook pages can be accessed at:

Since these are public pages, they are also accessible to users not registered on the platform. These pages are managed by the Communication and Marketing Office and are intended to provide information on the Company's activity and on how to access its services. In order to answer users' questions, the "direct message" function is active, protecting the privacy of the requests and messages sent by users.

LinkedIn pages

The UPMCI LinkedIn pages, a channel for sharing job opportunities with the Company, can be accessed at:

and are managed by the Communication and Marketing and the HR offices.

YouTube channels

The UPMCI YouTube channels can be accessed at:

and are managed by the Communication and Marketing Office. These channels operate as a virtual archive of videos of press conferences, events, interviews, radio and television broadcasts, video messages and institutional communication campaigns. Embedding (i.e., the possibility of incorporating) videos published on YouTube on a third-party website or blog is permitted, in compliance with copyright law. The published multimedia content meets the general technical requirements of YouTube.

Content (what we do/do not post on social media)

What we do post

On the various social network platforms users are informed about the latest regulatory and scientific news, services and initiatives of UPMCI, activities involving the Company and the Italian Ministry of Health, local authorities, hospitals, organizations, national and supranational associations and institutions.

Published content includes communications on activities and services, press releases, press articles, official publications and documents, information about initiatives and events, institutional images and videos and of events in which the Company participates.

After verifying the reliability of the source, the staff responsible for managing social channels evaluates and posts information of public interest conveyed by third parties (e.g., Ministry of Health, Regions, Local Health Authorities, public bodies and research institutes, media) to encourage the dissemination of information and user participation.

What we do not post

Information about matters of litigation or statements that could be used against the Company.
Confidential information, such as internal correspondence, third-party information (by way of example, institutions, users, stakeholders) or news on business activities, services, projects, and documents not yet made public, decisions to be taken and measures relating to ongoing proceedings, before these have been officially defined and formally communicated to the parties.
Personal information and special categories of personal data, including, but not limited to, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data relating to health or sex life or sexual orientation of the person, as well as genetic and biometric data.
Information relating to minors or incapacitated persons, except in cases where a specific and free consent has been obtained for publication on social media by the holder of parental responsibility or guardian.

Rules of conduct (netiquette)

The “rules of conversation” (netiquette) with network interlocutors are a dialogue pact, according to the following:

Everyone is allowed to express their opinion, with fairness and fairly, and to respect the opinions of others.
Everyone is responsible for the messages they send, the content they publish, and the opinions they express. Insults, vulgarity, offenses, threats and, in general, violent attitudes are not tolerated. The Company evaluates, depending on the case, the actions to be taken to protect its rights that may have been infringed.
The public interest of topics is an essential requirement for interaction: it is not possible to use these spaces for personal instances.
It is not permitted to use the Company's social media to communicate or transfer information or particular categories of data such as, for example, health data: if a similar content is posted it will be promptly removed to protect the persons concerned.
No form of advertising, spam or promotion of private interests or illegal activities is tolerated: if a similar content is posted it will be immediately removed and the author of the post notified.
Published contents must respect people's privacy: the publication of personal data (mailboxes, telephone numbers, current account numbers, addresses, etc.) of one's own or of third parties is prohibited. Otherwise, the content posted will be removed and the author will be reminded to comply with this policy.
Content that violates copyright and the unauthorized use of registered trademarks is not permitted. The Company undertakes to prevent and counteract this possibility, while the responsibility remains on the author of the post.
In the event of non-compliance with the rules contained in this policy, UPMCI reserves the right to delete contents, remove users from their virtual spaces and report them to the moderation filters of the host social network or, where appropriate, to the Postal Police or other competent authority. Comments and posts violating the conditions set out in this policy will also be removed.

Moderation

Moderation refers to the activity carried out by UPMCI staff during the interaction among users of the specific platform.

There is no preventive moderation: all users can intervene to express their opinion, following the rules of respect for others, education, and relevance. UPMCI reserves the right to remove content that violates these principles.

Insults or attitudes that damage the dignity of people will not be tolerated. In particular, the following will be removed:

content that promotes, favors, or perpetrates discrimination on the basis of gender, race, nationality, language, religion, political opinion, creed, age, marital status, status in relation to public assistance, physical or mental disability or sexual orientation;
content with inappropriate language and/or a threatening, violent, vulgar or disrespectful, deceptive or alarmist tone;
illegal content or incitement to perform illegal activities;
content that infringe copyright or misuse a registered trademark;
political content or propaganda (including, comments for or against political campaigns or voting indications);
content aimed at promoting commercial activities for profit;
content disclosing personal data and information or that may damage or harm the reputation of third parties in violation of current legislation, with particular regard to personal data protection (EU Regulation 2016/679 and Legislative decree 196/2003 as amended by Legislative decree 101/2018);
content of obscene, pornographic or child pornography nature, or such as to offend common morals and the sensitivity of users;
spam.
Furthermore, the following comments and contents are discouraged and in any case subject to moderation:
comments that are off-topic;
comments and posts written to disrupt discussion or offend social media moderators or other UPMCI staff;
messages entered repeatedly.

Messages and questions are appreciated, and the relevant staff are committed to responding to them.

Hours in which social media are overseen

Institutional channels are overseen, as a rule, from Monday to Friday, from 8.30 a.m. to 4.00 p.m..

Response times may vary depending on the type of request. Responses are provided, thanks to the coordination of the staff with the competent offices depending on the contents, within 48 hours of the request or, in the case of holidays, within the first two following working days.

UPMCI pages and accounts on social networks are not official channels that can be used to obtain specific and detailed information or to send reports or complaints. For these purposes, emails should be sent to info@upmc.it or to contacts listed in the Contact section of the website.

With the purpose of responding to the most frequent questions, UPMCI publishes and regularly updates news on institutional activity, services, and other information on its official website www.upmc.it.

Reference office for social media channels and contacts

UPMCI’s institutional social profiles are managed by different offices according to the reference channel as indicated below:

Communication and Marketing Office for Facebook, YouTube, and LinkedIn platforms, can be contacted at communication@upmc.it;
Recruitment and Retention Office for the publication of job opportunities and other content related to business activities on LinkedIn, can be contacted at hr@upmc.it for calls published on behalf of UPMC Italy.

Copyrights and Licenses

The contents of the Company's social pages, whether images, texts, audio files, videos or a combination of the latter, are protected by copyright law, the rights of which are reserved exclusively to the Company.

Pursuant to art. 1.1 of Legislative decree 72 of 22 March 2004, as amended by the Conversion law 128 of 21 May 2004, the works present on the Company's social pages have fulfilled the obligations arising from copyright and related rights legislation.

The reproduction, disclosure, public dissemination, public execution, and dissemination of contents of the Company's social pages without the latter's authorization is prohibited. The authorization to reproduce, communicate to the public, disclose to the public and disseminate the contents of the Company's social pages shall be deemed implicitly granted in the event that the content is shared only and exclusively through the use of share buttons.

Violations are subject to the sanctions provided for by the articles referred to in Section II of Chapter III of Law No. 633 of 22 April 1941.

Privacy

We inform you that during the consultation or use of the social channels used by UPMCI, information relating to users which constitutes personal data pursuant to Regulation (EU) 2016/679 may be processed directly. The processing of users' personal data complies with the policies in use on the specific platforms used. Sensitive data, posted in comments or public posts within the UPMCI social pages, will be removed.

The data shared by users through private messages sent directly to the social pages will be processed in compliance with current privacy regulations and subsequently removed, in compliance with the policy adopted and in consideration of the technical characteristics and limits of the specific social network platform used.

In no public digital space attributable to UPMCI will the discussion of individual clinical cases be allowed: this is highly confidential information which should only be discussed privately with specifically authorized clinical staff.

By posting a comment or other material on one of UPMCI's social pages, you agree that the Company will reproduce and use the contribution as deemed necessary.

For any additional information please refer to the privacy policy published in the appropriate section of this website.

Last update: March 2023