City of Atlantic Beach Guidelines for Elected and Appointed Officials Using Social MediaCity of Atlantic Beach
Guidelines for Elected Officials
and Board/Committee Members
Using Social Media
These guidelines are tailored for, but are not limited to, City Commission members and appointees to
City boards/committees.
1. Communication between City Commission members and appointees to City boards/committees via
social media, as with telephone and email, may potentially constitute a “meeting” under state
open-government laws and regulations. For this reason, City Commission members and appointees
to City boards/committees are discouraged from participating in social media discussions/threads
regarding City business, and are strongly discouraged from “friending” other City Commission
members and appointees to City boards/committees, and “liking” ot her City Commission members’
and appointees to City boards/committees’ posts.
2. Indeed, social media posts on private accounts about City matters are discouraged. That’s because
posts may be considered public records when they are made on a private account. This is
problematic because (1) they may be public records and, thus, should be archived (retention of
documents, including social media, is based on the content and not the platform); and (2) if two
City Commission members and or appointees to the same City boards/committees comment on
the same post, it may be considered a public meeting that should have been adequately noticed.
3. Receiving or making posts or comments regarding quasi-judicial matters via social media may
violate fairness doctrines and regulations. To avoid receiving comments on pending quasi-judicial
matters, City Commission members and appointees to City boards/committees are strongly
encouraged to maintain social media sites with settings that can restrict users’ ability to post
content.
4. Except for social media sites/tools that are owned or maintained by the City of Atlantic Beach,
which will be archived through the City’s archiving system, it is the ultimate responsibility of each
City Commission member and appointees to City boards/committee to maintain retention
procedures approved by the City of Atlantic Beach and to ensure those procedure are followed. As
with any correspondence sent in his or her capacity as a City Commission member and appointee
to City boards/committees, City Commission members’ and appointed board/committee members’
posting to non-City social media sites must be retained by the poster to the extent that such
content constitutes a “public record”. Printouts of postings to others’ sites may suffice for retention
purposes. City Commission members and appointees to City boards/committees should consult
with the City Manager and/or his/her designee for the applicable retention procedures.
5. To keep a personal account from becoming subject to public records, consider some basic
precautions.
Do:
i. Post a disclaimer on your personal account that identifies the account purpose and
that the opinions you express are your own. (A sample disclaimer is available from
the Deputy City Manager.)
ii. Notify visitors to your site about the Social Media Policy and Guidelines for the City
of Atlantic Beach by providing a link to the website containing the policy and
guidelines.
iii. Limit your personal account’s content to personal use.
iv. Have a plan in place to respond to or forward City-related comments to the City for
the purpose of public records retention and/or fulfilling a public records request.
Don’t:
i. Write posts on personal accounts that would fit within the “scope of employment”.
A court decision (Nissen v. Pierce County) outlines a test for when a post is created
within the scope of employment and, thus, is a public record. Scope of employment
may include elected officials acting within their capacity as City Commission
members or appointed board/committee members acting within their appointed
capacity. This includes when an employee, City Commission member, board or
committee member, or volunteer is (1) required by his/her job duties; (2) directed
by the employer; or (3) in furtherance of the employer’s interests.
ii. Discuss your private accounts in public meetings or documents.
iii. Link to your private accounts from an official city account.
iv. Use City devices to maintain your private account.
Questions or comments about these guidelines may be addressed to the City of Atlantic Beach
Deputy City Manager at info@coab.us or (904) 247-5804.
Updated December 2019