25 June 2021 - Social media marketing spend


25 June 2021

You asked:

1. What is the departments total spend on social media marketing between January 2021 and May 2021?

(a) What is the breakdown of this spend per channel?

  • LinkedIn,
  • Facebook,
  • Twitter,
  • Instagram,
  • YouTube,
  • TikTok,
  • Snapchat


2. What is the departments total spend on influencer marketing between January 2021 and May 2021?

3. What is the department's policy on employee social media use, if any?

Response to your request:

The answer to your questions are:

1. Nil 

(a) N/A 

2. Nil 

3. As Civil Servants, all of our staff are required to follow the Civil Service Code and comply with the Scottish Government’s HR Policies, code of conduct and our internal social media policy (attached).  

Attached internal social media policy:

Using Social Media

Internal Policy

1. Policy

Many staff will already be using social media in a variety of ways in their lives outside the office. This policy relates to staff use of social media as part of their work. It sets out the principles and standards you should adhere to as a Civil Servant regardless of whether you are acting in a personal or professional capacity. It also includes guidance on the difference between official, professional and personal use.

The Scottish Housing Regulator recognises the opportunities offered by social media and encourages staff to use social media in their work as a means to help achieve our statutory objective in ways that are consistent with our obligations as civil servants.

To this end:

  • We will provide training and guidance wherever possible to help you to make the most effective use of social media.
  • We will make it as simple as possible to access social media facilities from our network and remove barriers wherever we can.
  • We will support staff who use social media as part of their professional development.

2. Your responsibilities

Using social media in your capacity as a civil servant puts you in a position where you can affect the Scottish Housing Regulator’s reputation and standing, for better or worse. We therefore expect you to adhere to basic standards. We want you to be able to share what you are doing to progress the work of the Scottish Housing Regulator, but you must nonetheless respect our needs and the needs of the Scottish Housing Regulator, Scottish Government and wider Civil Service to protect its reputation, its legal obligations, its information, and its systems.

Because there is a risk, however small, of damage to the Scottish Housing Regulator, compromise of our IT systems, or breach of our legal obligations, we expect you to approach any use of social media platforms responsibly and with care.

We expect you to have discussed and agreed any official activity using social media which could impact the Scottish Government or its work with your line management, and with your Information Asset Owner (IAO)

Where you are using a public site or one which can have wider participation in which we don't necessarily know the audience, we expect you to have your intended use of social media documented as part of your wider communications plan, and to have discussed it with your IAO and colleagues in Communications.

  • Where you are sharing information on the internet, we expect you to have consulted your IAO) and document the risks arising should that information be lost or compromised. If information is lost or compromised we expect you to follow the Security Incident Management Process immediately
  • We may ask you to assist us in monitoring the Scottish Housing Regulator’s use of social media platforms and to assist us in measuring and reporting on the effectiveness of social media activity
  • We may ask you to work with us to capture and archive as public records any significant activity carried out on social media or collaborative platforms
  • We expect you to comply with other Scottish Housing Regulator policies (including the Data Protection Policy, Data Handling Policy, the Scottish Government IT Code of Conduct and Information Security Policy) when using social media and to be aware of (and stay within) the relevant legislative framework
  • We expect you to follow the general guidance issued relating to a social media exit strategy and to consider the points raised in that guidance very carefully before ceasing to use a platform or closing an account

3. Principles for use of social media

These principles are intended to underpin the use of social media across the Scottish Housing Regulator. They are not listed in any priority and should be regarded as mutually reinforcing. They should not be seen as detracting from, or supplementing, the Scottish Housing Regulator’s existing legal obligations regarding access to information and consultation. They are not intended to affect your use of social media in your personal capacity although staff should be aware of the general standards set out later in this document which affect you as an employee of Scottish Housing Regulator, regardless of whether you are using social media in your personal or professional capacity. There is also advice on engaging in social media on your own behalf and how you might want to differentiate between your personal and professional online activities.

The Civil Service core values of integrity, honesty, objectivity and impartiality, and the Scottish Government's aims, vision and values support good government and are fundamental to your ability to do your job effectively. Social media does not change this and you should take care to do nothing online that would damage the Scottish Housing Regulator’s reputation.

  • Be professional. You are a representative of the Scottish Government. In some networks you may be the sole voice of the Scottish Government.
  • Be transparent. If you are speaking in your professional capacity, disclose your position as a representative of the Scottish Government. And make it clear if you are speaking in a purely personal capacity.
  • Be responsible. Abide by the Civil Service Code of Conduct and the Scottish Government's IT Code of Conduct.
  • Be credible, accurate and fair. Stick to your area of expertise.
  • Be judicious. Libel, defamation, copyright, freedom of information and data protection laws apply.
  • Be integrated and inclusive. Go where people are. Make every effort to be accessible and connect with all relevant communities. Wherever possible, align online with offline communication.
  • Be personable, helpful and willing to learn. The 'social' in social media is there for a reason. It's not about delivering staid corporate messages. It is conversations between individuals and should be treated that way. When you gain insight share it with others
  • Be clear about your aims. Think about what you story you are trying to tell, to whom and why.
  • Be accountable. You are responsible for what you say online. You cannot cover up mistakes, you can only seek to correct them.
  • Be responsive and respectful. Visit frequently the online spaces where you have a presence and respond promptly to the conversations. Always pause and think before posting. When disagreeing with other opinions, keep it appropriate and polite.
  • Be careful. Never give out personal details like your home address or phone number.


  • Anything you post online is permanently available and open to being republished in other media.
  • You may attract media interest in yourself as an individual, so proceed with care whether you are commenting in a business or a personal capacity. If you have any doubts, take advice from your line manager.
  • The IT Code of Conduct already sets out clear guidance on the use of the internet and what might constitute misuse or unacceptable behaviour. Staff should ensure that they are familiar with the Code when they are considering how they might make use of social media. Any failure to be so will be looked at on a case by case basis but staff are reminded that breaches could, depending on the circumstances, result in disciplinary action being considered.

As soon as you identify yourself as an Scottish Housing Regulator or Scottish Government employee, speak in any kind of professional capacity or seek to use social media on Scottish Housing Regulator or Scottish Government business, there are certain responsibilities, standards of behaviour and other organisational considerations that apply. You are the public face of the Scottish Housing Regulator / Scottish Government and should engage online in the same way as you would with media or public meetings or conferences.

4. General Standards

As an employee, you must take the following into consideration when using social media in any capacity – personal, for professional development, or officially on behalf of the Scottish Housing Regulator:

  • If you are acting in your official capacity then make this clear and identify yourself and your role.
  • Be aware of your association with Scottish Housing Regulator in online spaces. Ensure your profile and related content is consistent with how you wish to present yourself with colleagues, customers and stakeholders.
  • Be aware of your language and conduct. The rules governing staff conduct apply. As in all cases where you are speaking in public, you should be aware of libel, defamation and slander.
  • Never share confidential or sensitive information. You should know and follow the rules on confidentiality and official information. You may have an inside track, so be aware of the rules on data protection and financial regulations.
  • Try to add value. Provide worthwhile information and perspective. The Scottish Housing Regulator is best represented by its people and what you publish will reflect on the wider organisation.
  • Try to frame what you write to invite differing points of view without inflaming others. So be careful and considerate. Once the words are out there, you really can't get them back.
  • If you're about to publish something that makes you even the slightest bit uncomfortable, don't shrug it off and hit 'send.' Review these guidelines and try to figure out what's bothering you, then fix it.

5. Tell your line manager

The Scottish Housing Regulator’s Social Media Policy emphasises that the use of such platforms can be a means to help achieve our statutory objective, and should be supported as a source of professional development of our staff. As you'd expect, that support depends on you keeping your managers informed of what you're doing or intending.

You must discuss any proposed official use of social media with your line manager – and generally your Director should be made aware.

  • If you wish to participate on social media platforms in a professional capacity, discuss it with your line manager first.
  • If you're in doubt about publishing something and can't decide if it's appropriate, discuss it with your line manager.
  • If you think you may have made a mistake, admit it in the same forum. Be upfront and be quick with your correction. Alert your manager or your Communications team early.
  • If you mistakenly publish something sensitive or RESTRICTED – even if you have been able to delete it – inform your line manager immediately.
  • It can be easy to start or get involved in a controversy unintentionally. It you think you may have stepped into a firestorm, raise it immediately with your line manager and your Communications team.

6. Engaging on behalf of the Scottish Housing Regulator

Social media is about the social connections and conversations we have with our customers, stakeholders and colleagues. To gain the maximum value from these tools, you should look to foster relationships. Therefore you will need to acknowledge and understand the commitment and investment of time in building and developing sustainable online relationships.

  • Understand the resources available to you to maintain and foster sustainable relationships.
  • Ensure you have the full support of your line manager before any official deployment of social media. Alert your digital co-ordinator and the Digital Communications Team
  • You are an ambassador for the organisation. Always disclose your position as a representative of the Scottish Housing Regulator. Anything you publish will reflect directly on the Scottish Housing Regulator as a whole.
  • Think through why you are deploying social media and what outcome you wish to achieve. For example, if you are inviting public responses then think through how you will use the results and how this fits in with other forms of consultation.
  • Think through potential risks and have plans in place to manage and mitigate these.
  • Respect your target audience. Think about their specific needs and be aware of language, cultural or other sensitivities you may need to take account of.
  • Seek permission to publish any information, report or conversation that is not already in the public domain. Do not cite or reference customers or stakeholders without their approval.
  • Respect copyright when linking to images or other online material.
  • Stay within the legal framework and be aware that data protection and financial regulations apply.
  • Have a plan for how you intend to monitor and evaluate the success of your activity.

7. Social media and Freedom of Information

If you engage on social media platforms in an official capacity, you need to be aware of the possible interactions with FOI/EIR legislation.

  • What you say on a social media platform (and indeed on other platforms such as text messages or private email accounts), even if you make the message private, may be subject to access legislation such as FOI or EIR.
  • A social media account that has the appearance of being official may be a legitimate way for someone to communicate a request for information (see the Information Commissioner's advice on this for guidance). So make sure you monitor such accounts (or close them down if they're no longer used).

8. Engaging on your own behalf

There are a number of benefits to social media, both for organisations and individuals. Many Scottish Housing Regulator employees will already be using social media in their personal lives. When you are not at work, it is, of course, entirely up to you to decide whether and how you choose to create or participate in a social media space or any other form of online publishing or discussion. This is your own business. The views and opinions you express are your own.

However, each of us represents the Scottish Housing Regulator to the world and the character of the Scottish Housing Regulator is defined by our beliefs and actions. We must be mindful of this when participating in social media and any kind of online communications.

Whether you are on your own time or Scottish Housing Regulator time, you are still a civil servant. And the judgment you exercise on your own time reflects on the judgment you exercise at work. There's only one you – at play and at work.

As a Scottish Housing Regulator employee it is important to be aware that posting information or views about the Scottish Housing Regulator cannot be isolated from your working life. Any information published online can be accessed around the world within seconds and will be available for all to see.

  • You are personally responsible for any content you publish.
  • Understand your online privacy settings – check your settings and understand who can see the information you publish and your personal information.
  • Follow the Civil Service Code of Conduct and the Scottish Government's IT Code of Conduct.
  • If you do talk about the work you do for the Scottish Housing Regulator or an Scottish Housing Regulator policy you are associated with you should make it clear that you are speaking for yourself and not on behalf of the Scottish Housing Regulator. Use a disclaimer such as "the views expressed here are my own and do not necessarily reflect the views of my employer".
  • Do not let your personal use of social media interfere with your job.

Be mindful of the personal information you disclose on social media sites, especially with regards to identify theft. Making information such as your date-of-birth, your place of work, and other personal information publicly available can be high risk in terms of identity theft.

9. Managing Your Digital Identity

There is a fine line with what and how much information to share with these different subsections of your life. Every public message you post on your Twitter account can be spread around the world in a matter of seconds and will possibly be indexed and found in real-time searches 24/7. These messages have the power to compromise your safety or your identity, jeopardize your future employment, or just embarrass yourself to the world.

  • Review and use privacy settings. Most major social media sites allow you to control how visible your information is on the site. You need to decide how visible you want your contact and profile information, videos, photos, and other posts need to be, and take the time to set the appropriate controls within the media site in question.
  • In most social media sites, you can limit who can see photos or video tagged with your name. You should consider how appropriate any video or photos are before you upload them. You also need to take advantage of any settings that allow you to control how visible this content could be if your friends have not exercised such good common sense.
  • Be especially careful of malicious links sent via social media accounts. In general resist the urge to click on links sent to you no matter the source.
  • Protect social media accounts from being hijacked. Use strong passwords. And be careful not to disclose your credentials. Using your credentials, attackers could use your account to lure your circle of friends into clicking a malicious link sent from your account.