Social Media Use in Telehealth Policy

1. Purpose

For a practice delivering services entirely online, social media intersects with clinical work in ways that are ethically sensitive and professionally consequential. This policy establishes comprehensive standards consistent with ACA, PACFA, AHPRA, and the Australian Privacy Act 1988 (Cth).

2. Scope

This policy applies to all practitioners and staff of Fields of Hope Counselling and covers all social media platforms including Instagram, Facebook, LinkedIn, TikTok, YouTube, and X (formerly Twitter), as well as personal practitioner accounts where their conduct may be linked to the Practice.

3. Practice Social Media Standards

• Content must be accurate, evidence-informed, and professionally worded.
• No client information — even de-identified — may be included without explicit written consent.
• All content touching on mental health topics must include a disclaimer that it is general information only, not a substitute for professional advice.
• All content must be reviewed and approved by the Practice Principal before publication.
• All accounts must have strong passwords, two-factor authentication enabled, and access revoked immediately upon a staff member's departure.

4. AI-Assisted Content Creation

Fields of Hope Counselling may use approved AI tools to assist with drafting or generating social media content. Where this occurs, the following standards apply:

• Practitioner review required. All AI-generated social media content must be reviewed and approved by a practitioner before publication. AI tools do not replace professional judgement about what is clinically appropriate to share publicly.
• No client data. Client information — including de-identified case material — must not be entered into AI tools for the purpose of generating social media content.
• Same standards apply. AI-generated content is subject to the same accuracy, clinical, advertising, and ethical standards as all other Practice content.
• Policy compliance. The use of AI in content creation must comply with the Practice's AI Use Policy, including requirements for approved platforms and data handling.
• Transparency. The Practice will not represent AI-generated content as the personal reflections or clinical opinions of the practitioner without practitioner review and approval.

5. Psychoeducational Content

Social media may be used for psychoeducational content — general information about mental health and wellbeing. This content must be general in nature, clearly distinguished from therapeutic advice, and must not imply or create a therapeutic relationship with followers.

Live Sessions & Video Content

Live content (Instagram Live, Facebook Live, YouTube) must include a clear disclaimer at the outset. Comments disclosing distress during live sessions must be responded to with crisis resources — not clinical engagement.

Sensitive Topics

Content addressing suicide, self-harm, trauma, or acute distress must include content warnings, follow Mindframe safe messaging guidelines (mindframemedia.com.au), and include crisis resources.

6. Advertising & Marketing

All advertising must comply with AHPRA Advertising Guidelines and the Australian Consumer Law. In particular, the Practice must not:

• Use client testimonials or endorsements
• Create unrealistic expectations about treatment outcomes
• Use before-and-after comparisons relating to mental health
• Make unsubstantiated clinical claims
• Target audiences based on health conditions or vulnerability indicators in paid advertising

7. Client Interactions on Social Media

Followers

The Practice will not proactively block clients from following public accounts. Practitioners must not follow back, like, comment on, or engage with the personal social media content of current or former clients.

Comments

Responses to client comments on Practice content will be general and non-clinical. Comments disclosing clinical concerns will be directed to phone or email. Comments that identify a client may be hidden to protect their privacy.

Direct Messages

DMs will be acknowledged and directed to appropriate contact channels. Clinical discussions will not take place via social media DMs. Where a DM contains crisis content, the Crisis Protocol (Section 9) applies.

8. Client-Generated Content

The Practice will not solicit or repost client-generated content. Where a client publicly shares identifiable information about their therapeutic experience, the Practice will not confirm or deny the therapeutic relationship. Negative reviews will be responded to generically and professionally — no client information will be disclosed in any response.

9. Practitioner Personal Social Media

• No client information — even de-identified — may be posted on personal accounts.
• Practitioners must not search for or monitor clients' personal social media profiles.
• Inadvertent discovery of client social media content must be documented and discussed in supervision.
• Case material must not be shared in online professional communities, even anonymously.

10. Crisis Disclosures via Social Media

Where a crisis disclosure is identified via any social media channel:

• Step 1 — Do not engage clinically via social media.
• Step 2 — Respond promptly with crisis resources: Lifeline 13 11 14 | Beyond Blue 1300 22 4636 | Suicide Call Back Service 1300 659 467 | Emergency 000.
• Step 3 — If the person is a current client, contact them via secure clinical channels as soon as practicable.
• Step 4 — Document the disclosure, response, and follow-up in the Practice's incident register.
• Step 5 — Debrief with a supervisor following any crisis disclosure.

11. Dual Relationships

Practitioners must take proactive steps to identify and avoid dual relationships online. Where an unavoidable digital dual relationship exists, it must be disclosed in supervision, documented, and addressed therapeutically. Practitioners must not leverage the therapeutic relationship to promote Practice social media accounts.

12. Privacy & AI Data Considerations

The Practice will not use social media platform analytics or advertising tools to target current or former clients. Meta custom audience features based on client data must not be used. Retargeting pixels or advertising trackers that could identify individuals seeking mental health services must not be installed. All personal information collected through social media interactions is subject to our Privacy Policy.

13. Related Policies

This policy must be read alongside:

• AI Use Policy — for standards on AI-assisted content creation, data handling, and approved platforms
• Privacy Policy — for data collection, disclosure, and APP compliance obligations
• Informed Consent & Client Agreement — for client acknowledgements about social media conduct and AI recording prohibitions

14. Review

This policy will be reviewed annually, or earlier in the event of significant changes in social media platforms, professional guidance on digital ethics, privacy legislation, or a material social media incident.