| Making things clear | | | | authority to intercept employees' communications, he |
| Policies are a set of documents that describe an | | | | must make reasonable efforts to inform people about |
| organisation's guidelines for operation and the | | | | interception. This is where communications policies |
| procedures necessary to fulfil these policies. Policies | | | | again come in, telling employees what may happen. |
| are often initiated in conjunction with the Business | | | | Employers may also have to consider how they make |
| Development department or because of some | | | | reasonable efforts to inform third parties. Can they |
| external requirement, such as business regulations and | | | | include this in their terms of business, on their email |
| possibly new legislation. | | | | disclaimer notices, on their web sites? As a basic |
| The Communications Policy will deliver HR policy | | | | checklist employers should develop a clear policy, |
| information and benefits in a consistent and effective | | | | communicate it to employees, create audit trails, |
| manner. These policies are maintained, reviewed and | | | | enforce the policy and consider alternative technical |
| updated by Human Resources in consultation, where | | | | means. |
| applicable, with Trade Unions. | | | | Consistency in enforcement of a policy is particularly |
| Policy manuals exemplify downward communication | | | | important. An employment tribunal, for example, may |
| intended to help employees perform their jobs. The | | | | not take kindly to evidence that an employee has |
| aim of the policy is to improve policy compliance and | | | | been singled out for action when a blind eye has long |
| have all the answers that an employee might ask in | | | | been turned to particular activities. If there have been |
| black and white. This will effectively reduce or possibly | | | | previous policies that haven't been enforced, then |
| eliminate calls to the HR department. | | | | employers should start again. |
| Fair and consistent treatment | | | | Where to begin? |
| HR policies and procedures can help organizations to | | | | A policy manual that can be anything up to a hundred |
| develop fair and consistent approaches to managing | | | | pages long can present a challenge for busy HR |
| and developing people and can protect against legal | | | | professionals. But take heart: the hard work has |
| claims. They can provide all employees with guidance | | | | already been done for you in the form of free |
| about their own and the organization's responsibilities. In | | | | download or purchasable software. An excellent |
| its introduction, the HR Communications Policy may | | | | example of a Communications Policy (governing |
| establish the principles upon which open, effective and | | | | authorized use of internet and email facilities assuming |
| productive communication should take place. | | | | that limited personal use is permitted) is available for |
| Policies need to be tailored to suit the culture, | | | | free download from which can be adapted to your |
| circumstances and size of an organization. For | | | | company's needs. |
| example, the policy may cover: publications, employee | | | | It contains the following sections: Introduction; general |
| surveys, suggestion scheme, board of directors' | | | | principles; use of electronic mail business use, personal |
| meeting, staff meetings, trade union membership, the | | | | use; use of internet and intranet; system security; |
| media, responsibility and media publicity. | | | | working remotely; personal blogs and websites; |
| As an organisation grows, or the environment in which | | | | monitoring of communications by the company; data |
| it operates changes, its need for HR policies and | | | | protection; compliance with the policy. |
| procedures will change. New policies will need to be | | | | A checklist |
| developed and formalized, or existing policies reviewed, | | | | The following is a checklist to be used in developing a |
| to ensure a consistent and fair approach - and to | | | | policy on employees' use of the employer's electronic |
| avoid wasting time by having crises dealt with in an ad | | | | communications and computer information systems: |
| hoc way. Introducing an HR policy doesn't mean that | | | | - Define what systems are covered by the policy, e.g., |
| the organization previously had no provisions in place. It | | | | voice mail, e-mail, Internet, and computer systems and |
| reflects a desire to formalize arrangements in certain | | | | files. |
| areas of people management and development for | | | | - Make clear that use of employer's computer |
| the reasons suggested. | | | | systems is to be used for business purposes only, and |
| Use of Communications Systems | | | | all files and messages are company property. |
| Having a Communications Policy is crucial today | | | | - If personal use is permitted, prohibit personal use that |
| because communication systems are not only an | | | | interferes with employee's work or that of others (e.g., |
| essential tool for doing business, but also an integral | | | | prohibiting non-work related websites such as chat |
| part of the daily work of many employees. Since | | | | rooms, games, travel, shopping, stock trading, hate |
| these systems affect virtually every organizational | | | | discrimination, pornography, etc.). |
| function, from customer service to production, | | | | - Prohibit inappropriate use including transmitting or |
| employers should adopt a communication systems | | | | downloading of material that is discriminatory, |
| policy that identifies the proper use of communication | | | | defamatory, harassing, insulting, offensive, pornographic |
| systems and encourages employees to explore new | | | | or obscene. |
| information resources. | | | | - Prohibit copying and sending any confidential or |
| This type of policy should provide information regarding | | | | proprietary information, or software that is protected |
| monitoring employee communications including | | | | by copyright and other laws protecting intellectual |
| telephone conversations, voice mail and e-mail, | | | | property. |
| improper use of employer equipment, opening mail in | | | | - Prohibit unauthorized access by employees of other |
| the office, and expectations of employee privacy. | | | | employees' electronic communications. |
| Human Resources Solutions | | | | - Notify employees that any misuse will be subject to |
| Employers are becoming increasingly frustrated at the | | | | discipline, up to and including termination. |
| amount of time employees spend on the internet or on | | | | - Inform employees that employer may access, |
| personal emails. Naturally, they turn to monitoring. But is | | | | search and monitor voice mail, e-mail or company files |
| keeping tabs on your staff justified or legal? | | | | of any employee that are created, stored or deleted |
| A Communications Policy can help with compliance to | | | | from company computer systems. |
| the law, but employers also have a number of | | | | - Advise employees they should not expect their |
| considerations, legal and practical, in arriving at a policy. | | | | communications or use of employer's computer |
| Should they ban all personal email and internet use? | | | | information systems to be confidential or private. |
| This solves the problem of having to distinguish | | | | - Have employees sign company policy or notice on |
| between personal communications and business | | | | acceptable usage of employer's computer information |
| communications (intercepting the content of personal | | | | systems. |
| communications is not authorized by the Regulations) | | | | - Consider installing an on-screen warning that appears |
| but may not be very popular with employees who | | | | every time employees log onto their computers. |
| often see email and internet as a perk of the job. An | | | | Introducing the policy |
| alternative is to offer employees use of a personal | | | | The culture of the organisation and the complexity of |
| template so that it is always clear when an email is | | | | the policies will influence how a policy is introduced. For |
| personal and the employer can ensure that it does not | | | | example, when it comes to communication, hard |
| monitor the content of these. | | | | copies could be given to employees or put on notice |
| Employees may have human rights concerns if all | | | | boards, or 'soft' copies circulated by email or placed on |
| personal telephone use is banned, so employers must | | | | an intranet. |
| consider what is reasonable and admissible, e.g. allow | | | | It is important for policies to be linked to business |
| reasonable use or provide pay phones. | | | | strategy, with a definite purpose for their creation. The |
| One of the key principles of The Data Protection Act | | | | communication process should be tailored to the |
| is telling people what is happening with their information, | | | | organization. |
| and this is where a Communications Policy is a useful | | | | Communications Policies are flexible documents, able |
| tool. One key advice to employers is therefore to | | | | to adapt to changes in strategy and direction. They |
| establish a policy and communicate it. | | | | are open and transparent, suited in tone to the culture |
| The policy must be uniformly enforced through | | | | of the organization and developed through the |
| employee education, ongoing monitoring and | | | | involvement of employees and interested stakeholders. |
| appropriate discipline. Obtaining prior consent also | | | | They need to be easily understood, written in plain |
| serves to diminish an employee's expectation of | | | | English and/or Maltese containing no jargon and be |
| privacy and will generally protect employers from | | | | communicated to all employees. The policy should be |
| liability. One of the key goals for an employer's | | | | in a format employees will use, be practical and |
| Communications Policy is to eliminate any employee | | | | enforceable, and with logical implementation. The |
| expectations that business communications are | | | | support of managers, including support from senior |
| confidential. | | | | managers, is crucial. |
| Interception policy | | | | © Copyright 2007, Commercial Services Bureau |
| Once an employer is satisfied that he has lawful | | | | (CSB) Ltd. |