Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
Type:
Policy
Name:
External communications policy
Purpose
This policy aims to ensure that Capital & Coast DHB’s (CCDHB’s) external
communication activity is fit for purpose and supports its organisational vision and
objectives.
This policy aligns with the External Communications Policy in place at Hutt Valley
DHB.
Scope
This is a CCDHB-wide policy and applies to all communication activity with external
stakeholders carried out by CCDHB staff or on CCDHB premises.
This policy applies alongside relevant legislation and regulations, and professional
and employment agreements and codes of conduct. Breaches of this policy may
result in disciplinary action.
Definitions
External stakeholders
This includes – but is not limited to – media, community groups, local and central
government and the general public.
Staff
This comprises CCDHB’s employees, Board and committee members, contractors,
students or other individuals carrying out paid or unpaid work at CCDHB.
Communication activity
This covers a broad range of activity. It typically comprises, but is not limited to:
media releases and interviews
published material, including posters, newsletters, reports and brochures
advertising
websites and social media.
Media management
The media has a legitimate interest in CCDHB and its activities. The DHB’s approach
is to be as open and helpful to the media as possible and appropriate, and to
recognise that they are an important means of communication with the public.
However, we do not believe it is in the best interest of our patients or CCDHB to
speak publically about individual cases, even if consent is given. Our preference is to
provide general comment.
External Communication Policy
Page 1 of 9
ID 1.103085
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document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
Media requests
The Communications Unit is responsible for liaising between the media and staff.
This approach expedites the flow of information to the media, reduces potential
disruption to hospital activity, and ensures media are getting accurate information
from the most appropriate person in the organisation.
All CCDHB-related media requests are to be referred to the Communications Unit as
soon as possible. The Communications Unit will work with the appropriate subject
matter experts and managers to prepare a response.
Media requests for patient information
CCDHB releases condition updates on request to the media in accordance with
CCDHB’s requirements and privacy legislation. Refer to appendix 1 on how the
communication unit responds to patient related media queries.
Authorised CCDHB media spokespeople
Only authorised media spokespeople or their delegate can comment on behalf of
CCDHB. This includes written and verbal comment. Refer to appendix 2 for the list of
authorised media spokespeople.
Media interviews will be undertaken only by spokespeople who have received media
training, are well prepared to respond, and have ensured any risks are minimised.
Media spokesperson for third party organisations
Staff who are spokespeople for professional bodies, committees or organisations
other than CCDHB can make statements, written or verbal, to the media to express
the views of that group.
In recognition of the rights and interests of the public in the health service, CCDHB
respects and recognises the right of its staff to comment publicly and engage in
public debate on matters relevant to their professional expertise and experience.
Staff must state the capacity in which they are speaking and make it clear that they
are not speaking on behalf of CCDHB.
The CCDHB logo, including uniforms or signage, is not to be visible in promotional
activity as it could lead the public to consider the activity is supported by CCDHB.
Approval must be sought from the Communications Unit to conduct face-to-face
interviews on CCDHB sites. Refer to the filming or photographing on CCDHB sites
section for more information.
Staff must inform the Communications Unit if they intend to, or have commented to
the media on behalf of a third party organisation that relates to the DHB or the work
of the DHB.
Proactively promoting CCDHB in the media
If staff wish to proactively promote CCDHB services or staff or invite media to attend
a CCDHB event, they must contact the Communications Unit prior to engaging with
the media. The Communications Unit will assess the request and, where appropriate,
provide communications support.
External Communication Policy
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ID 1.103085
Regard printed versions of this document as out of date – the CapitalDoc
document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
Legal liability
Staff making public statements regarding any person or organisation must comply
with relevant legislation including the Health Information Privacy Code 1994, and
Code of Health and Disability Consumers Rights 1996. Staff may be personally liable
if the statement is unfounded.
Remain impartial
While staff can act as advocates for patients, it is important staff remain impartial.
As a Crown entity, CCDHB must comply with the standards of integrity and conduct
set out in the code of conduct for the State Services. The code states that staff must:
maintain the political neutrality required to enable us to work with current and
future governments
carry out the functions of our organisation, unaffected by our personal beliefs
support our organisation to provide robust and unbiased advice
respect the authority of the government of the day.
Dealing with media
If the media contact staff directly, by phone or email, with a CCDHB-related media
request they need to be referred to the Communications Unit.
No direct dial, mobile phone numbers or email address of staff are to be given to the
media except for contact details of staff in the Communications Unit.
Concerns about media coverage
If staff have any concerns about media coverage, including the accuracy of
information, contact the Communications Unit to discuss. Any complaints about
media coverage are to be coordinated by the Communications Unit.
Promotional activity for third party organisations
Staff can take part in promotional activity for third party organisations in a personal
capacity. Examples of this would be featuring in marketing material or attending
events for an organisation other than CCDHB.
The promotional activity cannot be conducted on CCDHB sites or using CCDHB
equipment, including uniforms, as this could lead the public to consider the
promotional activity is supported by CCDHB.
Staff must inform the Communications Unit if they intend to take part or have taken
part in promotional activity for a third party organisation that relates to the DHB or the
work of the DHB.
No surprises approach
As a Crown entity we are required to operate on a no surprises basis to ensure our
Board, the Ministry of Health and Minister of Health are informed about issues.
Staff should inform the Communications Unit of issues that could attract media
attention or be contentious, as well opportunities for positive media coverage.
External Communication Policy
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ID 1.103085
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document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
If there is likely to be significant media coverage, such as a front page newspaper
article, an all CCDHB email with a summary of the media query and response will be
sent for the purposes of staff welfare.
Filming or photographing on CCDHB sites
Requests from external stakeholders to film or photograph on any CCDHB sites must
be approved by the Communications Unit. Filming or photography requests of a
commercial nature may incur fees.
The Communications Unit seeks advice to ensure the rights of patients, visitors or
staff are not breached, there are no health and safety risks, and there is no impact on
patient care. Appropriate consent from patients, visitors or staff must be obtained by
the external stakeholder.
Film crews must be escorted by a member of the Communications Unit, or their
delegate.
Conference presentations
External stakeholders are often present at conferences or seminars. Any presenter
who intends to make reference to CCDHB, its services, staff, or practices in their
presentation shall advise their professional leader or manager. This can be done in
any way acceptable to the professional leader or manager.
Published material
Following the CCDHB style and writing guide and using the corporate templates
means our published material looks professional and helps people to easily
recognise our organisation. Refer to the CCDHB style and writing guide on the
intranet for more information.
Any requests for the CCDHB logo to be included on material for an external
stakeholder must be approved by the Communications Unit.
Advertising
All advertising must be placed through the appropriate channel. For:
board and committee meeting public notices, contact the board secretary
recruitment advertising, contact the recruitment team
other advertising queries, contact the Communications Unit.
As a crown entity we follow the Code of Conduct for State Services which states we
must be impartial. All advertising displayed on CCDHB sites must be politically
neutral.
Commercial advertising
Offers from local businesses for staff are listed on the staff benefits page on the
intranet. The staff benefits are managed by the human resource department.
No commercial business can be advertised or promoted through CCDHB channels or
on CCDHB property without permission from the Communications Unit.
External Communication Policy
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ID 1.103085
Regard printed versions of this document as out of date – the CapitalDoc
document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
Official information requests
Any request for information held by CCDHB is covered by the Official Information
Act. An individual requesting their own medical records is excluded.
Requests for official information must be forwarded as soon as possible to
[email address]. Staff cannot respond to official information requests without following the process for
responding to Official Information Act requests. Refer to the Official Information Act
request policy for more information.
Website
The DHB’s websites are a key channel for keeping the public informed about our
services. Approval to set up any websites related to CCDHB or its services must be
obtained from the Communications Unit and relevant executive director.
The Communications Unit is responsible for managing the main external website
(www.ccdhb.org.nz) and making sure content is reviewed at least six-monthly. Staff
are responsible for informing the Communications Unit if content needs to be
updated outside of the six monthly reviews.
The administration and loading of content is only undertaken by the Communications
Unit or trained content editors.
Social media
The DHB recognises and supports the benefits of social media particularly in the
areas of public health information and recruitment.
You must be an authorised media spokesperson to post on publicly available social
media channels on behalf of CCDHB.
The Communications Unit regularly monitors social media channels to identify any
issues arising from unauthorised use and misrepresentation of the DHB.
Personal use
Staff participating in social media must make it clear they are doing so in a personal
capacity to avoid their personal views being misconstrued as the view of CCDHB.
Staff should not identify CCDHB as their employer when doing so would bring
CCDHB into disrepute.
Staff should not express any statement or comment that:
breaches patient or colleagues’ privacy
contravenes their employment or service agreement.
Contacting the Communications Unit
The Communications Unit is accessible outside normal business hours.
Phone the telephone operator and ask to be put through to the on-call media advisor
or email
[email address].
External Communication Policy
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ID 1.103085
Regard printed versions of this document as out of date – the CapitalDoc
document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
References
Department of Internal Affairs social media in government high-level guidance
CCDHB style and writing guide
Code of good faith for public health sector
Code of Health and Disability Consumers Rights 1996
Health Information Privacy Code 1994
Official Information Act request policy
Multi-employer collective agreements (MECAs)
State Services Commission standards of integrity and conduct
Appendices
Appendix 1: Responding to patient related media queries
Appendix 2: Authorised media spokespeople
Disclaimer: This document has been developed by Capital & Coast District Health
Board (CCDHB) specifically for its own use. Use of this document and any reliance
on the information contained therein by any third party is at their own risk and
CCDHB assumes no responsibility whatsoever.
External Communication Policy
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ID 1.103085
Regard printed versions of this document as out of date – the CapitalDoc
document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
Appendix 1: Responding to patient related media queries
This is a guide for the Communications Unit to ensure we respond to media queries
requesting information about a patient in an appropriate and consistent manner, and
key stakeholders are suitably informed.
Our preference is to provide general comment, rather than comment on specific
cases or individuals.
When seeking information about a patient on behalf of the media, the
Communications Unit will call the department or medical staff caring for the patient.
Patient condition updates
Under rule 11(1) (e) of the Health Information Privacy Code 1994, we can release
general information concerning the presence, location, and condition of a patient in a
hospital, unless the patient or their representative have expressly asked us not to.
When the media call requesting information on a patient we can confirm the patient is
in hospital, state the location the patient is in hospital and provide a condition update.
Terms used to describe locations:
Emergency department
Intensive care unit
Hospital ward
Inpatient mental health unit
Terms used to describe patient condition:
Being assessed in the emergency department
Critical
Serious
Stable or comfortable
We cannot confirm or provide any personal details about the patient such as their
name, nature of injuries or prognosis.
We cannot provide information about a patient who is not in hospital or patients using
community health services, including community mental health services.
If the patient is a high profile individual, such as a well-known sportsperson or
celebrity, we must seek permission from the individual or their representative.
If the patient has passed away, you can inform the reporter they are deceased once
the next of kin has been notified. If the next of kin has not yet been notified tell the
reporter “I’m not able to provide an update at this time”, take down their details and
call them back.
If you are not able to identify the patient from the description provided tell the reporter
“based on the details provided we do not have a patient that meets this description”.
Actions by the Communications Unit:
Inform the chief operating officer if there is a high profile individual in the
hospital in case additional privacy or security measures are required.
External Communication Policy
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ID 1.103085
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document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
Media request for additional patient information
Under Rule 11(1) (b) of the Health Information Privacy Code 1994, we can release
information about a patient if the disclosure is authorised by the individual concerned,
or the individual’s representative where the individual is dead or unable to give their
authority.
If the media ask for additional information about a patient, consent will need to be
provided by the patient or their lawful representative. For a minor under 16 years
their parent or legal guardian, and for adults not capable of consenting their welfare
guardian or person acting under enduring power of attorney or a person clearly
acting in the best interests of the patient.
Send the following response and media consent form to the reporter – “We are
unable to provide you with the requested information about a patient as their consent
is required under the Privacy Act 1993.”
It is the reporter’s responsibility to get consent. If consent is not provided, we can
only provide a patient condition update or general comment.
If consent is provided we are able to disclose information to the named media outlet
for the purpose outlined. Unless the media consent form says all media, consent is
required for each media agency.
Even if consent is granted, we still must consider the impact the information released
to media may have on the patient, their family and staff. The Communications Unit
will consult with clinicians to ensure the information provided to the media is relevant,
accurate and won’t have a detrimental effect on the patient and their family.
Actions by the Communications Unit:
Notify the manager and/or clinical leader of the department as well as the
relevant Executive Leadership Team (ELT) member of the media request as
soon as possible
Send a media update email at the end of the day to the board, ELT members,
Ministry of Health and the Minister’s Office
If there is likely to be unfavourable media coverage, provide a copy of the
response to the manager and/or clinical leader of the department so they can
inform their staff
If the media coverage is likely to be significant, such as a front page
newspaper article or TV news coverage, send an ‘ALL CCDHB’ email with a
summary of the media query and response. The purpose of this email is to
appropriately forewarn staff of unfavourable media coverage. Information
should be limited to a broad description of the issues and no identifying
details are to be included.
Include the media request, response provided and outcome in the weekly
media report.
Media request where the patient is involved in a police investigation
Follow the same guidelines for patient condition updates. If the individual dies,
contact the Police communications team to find out if they will be issuing a
statement.
External Communication Policy
Page 8 of 9
ID 1.103085
Regard printed versions of this document as out of date – the CapitalDoc
document is the most current version
Document facilitator: Director of Communications Capital & Coast and Hutt Valley DHBs
Senior document owner: Executive Leadership Team
Document number: 1.103085
Issue Date: 14 February 2020
Review Date: 14 February 2023
Appendix 2: Authorised media spokespeople The authorised spokesperson will decide on an individual basis if they delegate the
spokesperson role and who they delegate it to.
Subject/issue
Authorised spokesperson
Or delegation
Deputy Board Chair
Hospital Advisory Committee
Governance or
Board Chair
chair
political
Chief Executive
3DHB Community & Public
Health and Disability Support
Advisory Committee chair
Service planning
Chief Executive
and allocation of
Director of SPP
Senior Portfolio Manager
funds
Chief Financial Officer
Directorate executive
Chief Executive
Wellington Regional
directors – operations and
Director Provider Services
Hospital
clinical
Chief Medical Officer
Kenepuru Hospital
Clinical heads of
Chief Nursing Officer
Kapiti Health Centre
departments
Chief Allied Health Officer
Specialist staff
Directorate executive
Mental health,
directors – operations and
addictions and
Chief Executive
clinical
intellectual disability
General Manager MHAIDS
Clinical heads of
services
departments
Specialist staff
Chief Executive
Community services
Senior Portfolio Manager
Director of SPP
Public health physician
Public health and
Medical Officer of Health
Programme managers
health promotion
Director of SPP
Health protection officers
Emergency
Chief Executive
Specialist staff
management
EOC controller
Chief Executive
Information services
Senior ICT staff
Chief Digital Officer
External Communication Policy
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