Be extra careful using social media
Social media can be a great tool to promote your independent practice – provided you follow a few simple rules, says Dr Udvitha Nandasoma.
There are an estimated 56.2 million active users of social media in the UK.
And according to the latest Digital 2024 Report, the UK is in the top ten countries for social media use as a percentage of the population – 83% compared with 78% in France and 70% in the US.
With such a large potential audience, it makes sense for your practice to have a presence on social media platforms and many doctors also find it useful for networking or to discuss healthcare topics with colleagues.
But while social media can be a great asset to build your brand and advertise, it is not without professional risks.
Doctors are not like regular members of the online community – you can be held accountable by the GMC and other regulators for things you post, like or share, even if they do not relate directly to your practice.
So, if you want to be a social media supremo and avoid difficulties, we have some useful advice:
Keep control of your content
Take a moment to review content before posting to ensure you have not written anything that could be seen as inadvertently misleading, made claims about a service that cannot be objectively justified or omitted relevant information.
You must also ensure that you are not straying into areas outside of your expertise.
You might need to take more care about the precision of your posts than when using social media with friends or family.
The GMC’s new guidance on Using social media as a medical professional emphasises that doctors’ conduct should justify patients’ trust in you and the public’s trust in the profession.
If you are posting about medical issues, it’s important to be clear about your credentials and be able to substantiate and justify what you say.
If advertising your practice or promoting other services or products, the GMC says you must ‘comply with relevant law, guidance and regulatory codes including those from the Committee of Advertising Practice (CAP), the Advertising Standards Authority (ASA) and the Competition and Markets Authority’.
Strict rules
There are strict rules in place to regulate social media promotions from the ASA.
It needs to be made clear if any account, including but not limited to a social media influencer and/or celebrity, has been paid to promote your services.
Paid promotions must be clearly defined as such at the start of the post caption, and clearly visible on posts such as Instagram Stories, with the hashtag #AD or #Advertisement. In-platform ‘Paid promotion’ labels may be used in addition, but aren’t sufficient on their own.
Even if a post does declare it is a paid-for advert, it can still be problematic if the information is inaccurate or biased.
Using social media to promote cosmetic services can be especially problematic and you should ensure content is in line with the relevant CAP guidance as well as avoiding promotional tactics such as competitions – prohibited by the GMC – that could encourage people to make an ill-considered decision.
In addition, prescription-only medicines (POMs), including botulinum toxin, cannot be advertised directly to the general public on social media under the Human Medicines Regulations 2012. Even using hashtags like #botox could amount to promotion of a POM and might fall foul of those regulations.
Finally, if you employ someone to manage social media content for your practice, they should have clear guidelines and policies to follow and effective supervision.
There are obvious dangers in giving someone access to your own social media accounts to post on your behalf.
Maintain confidentiality
The GMC emphasises the importance of maintaining patient confidentiality and respecting their dignity and right to privacy when using any social media, including private forums and messaging groups.
Even if you have been careful not to disclose too much, be alert to the risk that information in several different posts might be enough to identify someone – known as jigsaw identification.
Before using testimonials or images of satisfied patients on social media sites like Instagram, you need to explain what information you intend to post, where it will be posted, for what purpose and to what audience and obtain their consent.
The need for explicit patient consent, ideally in writing, applies whether or not you think they are identifiable, as set out in the GMC’s Making and using visual and audio recordings of patients.
Be transparent about your interests
In its social media guidance, the GMC also says: ‘If you use social media to advertise your services, or use your professional position to promote or endorse any other services or products, you must be open and honest about any interests you have that may influence – or could be seen to influence – the recommendations you make.’
Failing to be up-front about direct and indirect financial incentives can raise serious concerns about your probity.
In Identifying and managing conflicts of interest, the GMC gives examples of potential conflicts and states that ‘trust can be damaged by the perception that a medical professional may be prioritising their own interests above patient care, even if the medical professional is confident their interests have no influence over the way they practise’.
A social media policy should help pre-empt problems, but if in doubt, it’s better to check with a colleague first than rely on your own assessment.
Don’t be a keyboard warrior
It is not just your posts that matter, but also your comments and interactions with others on social media.
The GMC’s social media guidance states that a doctor’s communication online should meet the same standards as would apply face to face: ‘You must not use social media to abuse, discriminate against, bully, harass or deliberately target any individual or group.’
The GMC states that doctors ‘have rights to freedom of belief, privacy and expression’ on social media, but you also need to take account of ‘the possible impact on other people’s rights and interests’.
For this reason, it is important to remain measured and professional and do not allow yourself to be caught in a war of words with another poster or organisation.
Social media is not really a place for nuance or banter: even if you believe your words cannot be taken seriously, others might have an entirely different view of a light-hearted post and things can escalate quickly.
Maintain professional boundaries
Having a social media profile means there is a risk of unwanted approaches from patients and others seeking personal advice or reassurance.
Responding would be a mistake, as this is likely to establish a duty of care that could leave you vulnerable to a clinical negligence claim or complaint and it would be difficult to justify giving medical advice to an individual without access to all the relevant information.
Worse still, the patient might be based in a different jurisdiction where you are not registered or indemnified.
More generally, we recommend that you avoid communicating with patients through personal social networking sites, adjust the privacy settings of your social media accounts and do not give out personal information.
The GMC says that patients who contact you though your private social media accounts should be directed to an appropriate healthcare setting and points to its guidance on Maintaining personal and professional boundaries.
Social media is a useful channel for promoting your practice and raising awareness, but it’s much better to have a plan and think about your posts rather than attempt damage limitation after a mistake has gone viral or attracted the attention of the GMC. Contact your medical defence organisation if you need specific advice.
Dr Udvitha Nandasoma (right) is the head of advisory services at the Medical Defence Union (MDU)
