Social media can be seen as a resource for increased interaction between municipal authorities and citizens. However, as authorities attempt usage of social media, practices can become entrenched in traditional regulatory frameworks that emphasize openness and transparency rather than interaction with citizens. Social media usage by authorities tends to touch upon a broad range of regulatory elements, some of which are legal in character and others that we see as embedded in the technologies themselves as well as practices developed in connection with the technologies. In this paper, 26 Swedish social media policies produced by municipalities are analyzed in order to better understand how the conflict between transparency and interaction is dealt with in practical guidelines. We are concerned with how the diversity of social media is understood and how public functions are identified. By analyzing challenges and policy strategies outlined in these documents, it becomes possible to identify four alternative foundational positions based on social media being perceived as a problem/possibility or homogeneous/heterogeneous. The general tendency in all material is that routines of command and control are established in order to create clear goals and practices for individual social media activities and thereafter to discipline social media activities to remain firmly within the intentions of the blueprint. This explicitly disallows activities to adapt to needs developing through interaction with citizens. Nevertheless, we have also found a number of participatory strategies that are either aimed at increased quality of community services or at extending the marketability of the municipal brand.
It is possible to visualize the breakthrough of social media in three phases. In the first phase, new applications for Web–based social interaction, such as MySpace, YouTube, Facebook and Twitter, found a huge and global customer base. In the second phase, gaining momentum around 2007, the corporate world attempted, with increasing success, to utilize social media for commercial advantages. We identify the third phase as governments and governing bodies initiate systematic presence within social media.
It is this third phase, starting around 2009, that is in focus in this paper. The task for authorities of establishing a presence within social media is actually a distinctly different genre compared with corporations and private individuals. While corporations can be quite flexible when working in social media, governing bodies are bound by a regulated system that defines an appropriate relationship between civil servants and those contacting the authorities.
Early experiences within social media served to raise a number of warning flags. The traditional media quickly discovered that they could exploit social media as a source for scandals as various civil servants and politicians tended to be informal and unguarded. Many authorities discovered that social media often introduced new problems that traditional regulation on the Internet did not cover.
Starting in 2010, several authorities in many countries attempted specific guidelines for how civil servants should work with social media. In Sweden, the empirical focus of this study, a number of municipalities initiated work on a “social media policy”.
The first of these policies came in April 2010 and altogether at least 26 municipalities produced such a document during 2010. These policies are, seemingly, produced locally at the different municipalities, as there is limited overlap between them. Therefore, they constitute 26 different strategies in thinking about social media as a tool for municipalities. At the end of 2010, a governmental body dubbed the “E–delegation” produced guidelines (E–delegationen, 2010) that were intended as a support for all governmental bodies. Although rich in regulatory advice, it is our impression that these official guidelines actually attempt to discipline the social media activities of authorities in order to force them into the mold of established regulatory practices.
The Swedish example is of specific and general interest in three ways. First, this is a country that has been an early mover on social media in general. Second, Sweden has an effective administrative organization on both national and municipal level and is therefore often an early mover on new regulatory issues. Such is also the case with social media policy. Third, Sweden has among the world’s most generous legislation on freedom of access to official records. In practice, everything that is produced by civil servants, and not deemed as classified, is freely available to all citizens. This generous idea of public access actually generates specific, and quite severe, problems when formulating social media policies. We will argue that the democratic intentions of the Swedish principle of freedom of access to official records are turned on its head when adapted to social media policy.
Social media is a form of communications technology and the potential of the medium is to support increased interaction between citizens and municipalities. Therefore the purpose of this article is to analyze the ways in which the municipalities’ social media policies are sufficient or insufficient in allowing municipalities to utilize the full potential of social media technology. In order to provide a foundation for the analysis of social media policies this work will utilize the following research questions:
- What concepts of social media and public functions are identified?
- What challenges, concerning social media, do municipalities identify?
- Which policy strategies have been selected to address these challenges?
The article will start with an introduction to the foundational idea of regulation: command and control. Earlier research has discussed how the Internet is difficult to regulate, placing a strain on the command and control structure. We will also review the Swedish legal context, highlighting two regulative principles: that of the civil servant as employee and freedom of information access. Thereafter we will present two theoretical viewpoints. The first of these is an updated version of Marshall McLuhan’s famous idea that it is the technology that controls the content, not the other way around. The second viewpoint is a notion of conflicting regulatory elements. Traditionally, different regulatory areas are seen to exist within a hierarchical structure. Conflicts are solved by allowing priority to higher order policies. We will argue that regulation on social media tends to enter an area where the hierarchical levels become flattened.
Following the theoretical section, we will present the empirical material. We will discuss our findings in relation to the empirical research questions. The article will conclude with a discussion.
2.1. Dilemma of Internet regulation
One of the challenges with the creation of Internet–based communications systems is the strain placed upon command and control (C&C) regulation. C&C is a principle that views regulation as system of statutory rules backed by sanctions (Black, 1997). A side effect of ICT, from the C&C point of view, is its widespread dissemination in developed countries as the communications infrastructure of choice. This side effect comes from the Internet’s capacity to be a nondiscriminatory data transportation system, i.e., the content being transmitted is not controlled and therefore regulating through C&C is aggravated.
Since controlling the user becomes more difficult it is necessary, in order to create efficient rules, to create “compliance oriented” regulation (Baldwin, 1995), i.e., to design rules in such a manner as to promote the ease in which they could be adhered to. However, it must be understood that the creation of regulatory rules is a process of simplification. There are two aspects to this. First, a simplification of language, clarity is pursued, disallowing ambiguities. Second, rules must be built on simplified understandings of reality as this enables large groups of regulated subjects to fall within the scope of purpose. The rule is not only by its nature a simplification of an existing (and more complex) understanding of reality; it is also “hostage to future developments” (Black, 1997) that may utterly change the meaning and purpose of the rule. These latter problems become obvious in times of rapid technological change when rules based upon one presupposition of technology are suddenly being applied to a new technological infrastructure with very different results.
In the case that we are analyzing, social media policies, the regulatory tradition has been to apply the routines connected to the administration of paper to be valid for digital technology as well. As response to the first waves of digitalization, in the 1970s, 1980s and 1990s, this strategy has been successful. However, as social interaction becomes more flexible in recent years, one can question the continued application of older regulatory ideals.
Social media policies challenge us to rethink the notion of Internet regulation. According to the classical command and control principle, we can subject human conduct to the governance of external controls no matter which forms such controls consist of (Baldwin, et al., 1998). Naturally, with such a wide definition of rules, the regulated subject must negotiate complementary and conflicting regulatory systems.
2.2. Technology and norms
Any pragmatic attempt to understand the regulation of online activity must begin with an understanding of the technology itself. In particular, it is important to understand the affordances and limitations set by the technological infrastructure. It is outside the frame of this paper to fully describe the various technologies of social media. Instead, we build on general theoretical idea that the design of a technological artifact or system is not neutral but, rather, have a strong effect on our use. For our purposes, we see a social media platform as an artifact and the technological artifact embedded in a regulatory framework as a technological system.
Our position is similar to that of Smith (2000), who argues that different technological systems signal separate norms of behavior. For instance, a technological system that removes personal choice, either through technology or regulation, would indicate that the moral values reside in the technological system. On the other hand, if the system through design and regulation upholds personal choice, the individual becomes empowered to be a moral agent.
Among the earliest researchers to broaden this discussion and to present it to a wider audience was McLuhan (1964) who argued that changes in the technology have wider effects on what we communicate. In essence, the technology controls the content. The recent widespread adoption of social media has seen a renewed interest in McLuhanism (cf., Keen, 2007; Carr, 2010; Lanier, 2010).
Despite this fresh round of technology criticism, the prevailing wisdom is that technology and society are easily separated into isolated domains (Beck, 1992). One reason for this may be the reluctance to accept any form of technological determinism, as this would imply a lack of free will among human actors (Winner, 1980; Feenberg, 1991).
A counter to this may be found in the substantive theory (Ellul, 1980) that technology constitutes an alternate cultural system that is transforming the entire social world. Technology is, then, seen as a tool that actively shapes patterns of thought and behavior. Winner (1980) and Latour (1992) have extended this questioning of the neutrality of technology.
This theoretical discussion on the restrictions imposed by technological choice, should be linked with a discussion on the potential of technological development. Technologies do not only restrict human behavior, they can also be liberating. The concept of affordances was suggested by Gibson (1977) and adapted to the technological discussion by Gaver (1991).
Built into the concept of affordances are both restrictions and possibilities, although we will focus on the latter in this text. In other words analog, paper–based publications contain certain affordances that are quite restrictive compared with digital text. Web–based publications offer even more affordances and social media further widens this range. Nevertheless, we will discuss policy approaches that view social media with the mindset of analog, paper–based affordances.
By combining these two approaches, we suggest that to understand the political practice of the 2010s, we must be aware of both the affordances and restrictions of available technologies.
2.3. Regulatory elements
When studying different government bodies’ attempts to regulate social media use among their staff, we have found it useful to visualize processes of balancing contradicting elements of regulation. The position of this work is that regulation should be seen as any force or external control exerted upon those actions to be regulated (Fuller, 1964). Therefore regulation can be state or non–state, intended or unintended, legal, technical or economic and so on. As Fuller himself noted, “A possible … objection to the view [of law] taken here is that it permits the existence of more than one legal system governing the same population. The answer is, of course, that such multiple systems do exist and have in history been more common than unitary systems.” 
As we take our starting point by recognizing the existence of polycentric regulatory systems we are able to more fully understand the ways in which systems other than law exert regulatory pressure.
The fundamental level of regulation lies mainly outside the control of the governmental authorities and consists of the affordances and limitations of the technology under consideration. While some Internet applications may be blocked by organizations, this is a coarse form of regulation, which may not take into consideration the full needs of the organization. Additionally, such limitations are restricted to those Internet access points controlled by the organization.
Aside from the technological limitations that may be set there are legal systems that affect the behavior of the social media user. Four of the more central areas of law in relation to social media use among government employees laws concerning individuals’ rights, employment law, administrative law and criminal law.
Figure 2: Polycentric regulation: Elements regulation for social media use.
There are three aspects that create major complications when applying these traditional regulatory ideas on social media. The first of these is that the command and control principle presupposes that the technology that is to be regulated is a neutral instrument. As we have argued above, this is seldom the case. Furthermore, social media are so blatantly non–neutral that it clearly supplies new possibilities, affordances, dissolving or renegotiating boundaries between the four legal systems mentioned above.
The second complication concerns the way that social media obviously has the potential of rejuvenating and actually revolutionizing the relationship between politics, governmental bodies and citizens. From our perspective, this should be the primary consideration when devising policy. However, as we shall see, this is, at best, a secondary aspect of the policies that we have studied.
The first complication is, quite simply, that regulation tends to restrict the affordances of the technology. Therefore, regulation, originally aimed at promoting democracy, may actually restrict the participatory potential of social media.
2.3.1. Employee loyalty
Modern regulation is often built on quite old solutions to ancient problems. This is important to keep in mind when analyzing aspects of social media that can be seen to introduce new dimensions to old problems. An important tradition for the Swedish regulatory landscape goes back to conflicts on the labor market during the late nineteenth century. In 1906, recognizing the inefficiency of conflict in the labor market, representatives for employers and employees initiated the negotiations, which eventually led to the so–called “December Compromise”. This created a fundamental recognition of the employee’s right of union organization and the right of the employer to lead and distribute work. From this latter right stems the employer’s right to organize production. Included in the right to organize production was the authority to create rules and policies within the sphere of employment. As such, policies may be seen as statements expressing the intention to control the behavior of the employees.
In addition to the former principle, the employee is also bound by a duty of loyalty towards the employer. This duty has often been affirmed by the courts and consists of a duty not to cause harm to the employer. Taken together, the employer–employee relationship consists not only of an economic agreement but creates a personal relationship between the parties that go beyond those stated in the employment contract. Failures in loyalty may lead to lawful termination of the employment contract.
Therefore, while the December Compromise established the principle of the employer’s right to direct work, this power is not absolute — it does not automatically suspend civil rights of individuals. However, it is important to establish that the duty of loyalty creates a limitation to the right of the employee to openly criticize the employer. This explicit contradiction between the rights of the citizen and the loyalty of the employee is given a new dimension as corporations and authorities allow their representatives to work with social media on their account.
2.3.2. Freedom of access to official records
As this paper analyzes social media policies within Swedish municipalities it also deals with rules beyond the complexities of the employee–employer relationship. Municipalities in Sweden are public authorities and, as such, are bound by the legal obligations of Offentlighetsprincipen and Meddelarfriheten.
Offentlighetsprincipen is the freedom of access to official records. This right was first introduced in Sweden through the Freedom of the Press Act of 1766. However, with the introduction of the computer, authorities were able to distinguish between the information bearer and information content. In recognition of this, two important changes have been made to Offentlighetsprincipen. In 1974 the freedom of access to public documents was deemed to apply to computer systems and in 1976 the principle was deemed to apply even when the data was not stored as documents. It is important to emphasize that according to the guidelines issued by E–delegationen (2010), material on social media falls under the rules pertaining to Offentlighetsprincipen. In other words, any communication through social media is to be publicly available to any citizen requesting access.
Meddelarfrihet is the right to communicate public documents to the press as long as publication does not conflict with the legal obligation of crimes such as treason or espionage. However, it is important to note that the principle of Meddelarfrihet also limits the right of public authorities to investigate the source of incorrectly spread, or leaked, information. Therefore, in most cases, public authorities are not authorized to investigate the identity of the source of leaked material.
To sum this up, Swedish authorities have become accustomed to functioning within an ideal of democracy where the work of the governing bodies is almost totally transparent. At the same time, public authorities have been given the right to regulate employee behavior through policy documents. Taken together, this regulation has served to promote a culture of “doing things by the book”. Obviously, the almost chaotic communication structures of social media constitute a challenge to such a culture.
Sweden is divided into 290 municipalities with populations ranging between 2,460–847,073 . Each municipality is responsible for social services, care of elderly and handicapped, childcare and schools, planning and zoning, environment and health protection, public cleaning and garbage management, fire brigade, water and waste, order and security. In addition to these areas the municipality may also play an active part in recreational activities, culture (but not libraries), housing, energy, business and reception of refugees.
We aspired to collect all social media policies produced by Swedish municipalities during 2010. The choice to collect data from 2010 was logical as the first Swedish municipal social media policy appeared in March of 2010 and in December 2010 the governmental authority given a mandate to develop regulations for social media published its report (E–Delegationen, 2010). Therefore our data reflects the initial attempts of municipalities to regulate the social media phenomenon on a local level. Through regular Web searching, we identified 14 policies and by querying key informants, we were able to locate an additional 12 documents. Since commencing work with this paper all 26 policy documents are available online and are at present also collected on the Web site of Sveriges Kommuner och Landsting (Swedish Association of Local Authorities and Regions, at http://www.skl.se/). These texts varied greatly in length and ambition, from a few paragraphs to 20 pages. Starting in March, the policies were spread out over the year.
Table 1: Social media policies: 26 social media policies investigated in this article. Note: SM = social media, N/A = information not available. Municipality Translation of title Date Word count Accepted by Malung–Sälen Social Media (SM) March 428 Municipality Chief Committee Katrineholm SM use Guidelines April 1328 Municipality Executive Committee Arvika SM Guidelines May 2344 Director of Administration Härnösand Guidlines for how Härnösand Municipality shall conduct oneself in SM May 1914 Office of the Municipal Goverment Tomelilla SM May 642 N/A Sundbyberg SM use Guidelines for the City of Sundbyberg May 951 Director of Administration Tierp Strategy for SM for Tierp’s Municipality May 492 Municipality Executive Committee Halmstad Guide for use of SM June 3173 Municipality Executive Committee Hammarö Guidelines for use of SM June 327 Municipality Executive Committee Kalmar Guidelines SM June 1231 Municipal Chief Executive Linköping Guidelines for the municipalities external website June 329 Municipality Executive Committee Lilla Edet Advice for SM June 899 N/A Karlstad Strategies and Guidelines SM July 3449 Office of the Municipal Goverment Ljungby Guidelines for use of SM August 785 Municipal Chief Executive Karlskrona Guidelines for use of SM August 780 Municipality Executive Committee Västerås Strategy for SM use in the City of Västerås September 7556 Municipality Executive Committee Rättvik SM Guidelines September 414 Municipality Executive Committee Vingåker Guidelines — Use of SM September 483 N/A Norrköping SM use Guidelines October 852 Director of Administration Trelleborg SM Guidelines for the Municipality of Trelleborg October 2964 Municipal Chief Executive Kumla SM Guidelines in the Municipality of Kumla November 2849 Municipality Executive Committee Tyresö SM use Guidelines November 1657 Municipality Executive Committee Nyköping SM use Routine November 2573 Municipal Chief Executive Kalix SM use Guidelines in the Municipality of Kalix December 1085 Municipality Executive Committee Lidingö SM Rules and Guidelines for the City of Lidingö December 2059 City Executive Committee Ystad SM use Guidelines for authorities in the Municipality of Ystad December 2217 Municipality Executive Committee
3.1. Conceptions of social media and public functions
The image of social media varied greatly among the different policies. In many cases, social media was carefully defined at the outset of the document. However, just as often the texts started with an outline of the policy problem(s) of regulating these forms of communication in accordance with national legislation.
It is possible to identify two different images of social media in public functions here, as only a problem or as also a resource. To clarify this, social media is always seen as an administrative problem, but in some cases it is also seen as a resource. These perspectives can be linked to our theoretical ideas of restrictions and affordances. In other words, social media can be seen as something that only needs to be disciplined or as something that also contains an opportunity for engaging in new practices. It is here important to note that the E–delegation supplies guidelines along the perspective of social media primarily as a problem.
A second dividing line concerning the image of social media relates to if this is a category of a number of homogeneous or heterogeneous platforms of communication. This is a crucial starting point for any social media policy.
Guidelines are made clearer and easier if it is assumed that one can produce general guidelines that are just as appropriate for YouTube, Wikipedia and Facebook. This homogeneous position also tends to view situations that continuously appear when managing a presence at social media as predictable. However, if social media is seen to refer to a number of applications that are very different in character, constantly producing unique dialogs, then guidelines will have to be stipulated for individual social media and for a wealth of different situations.
Broadly speaking, this dividing line seemed to account for differences in document length. The heterogeneous perspective on social media automatically raised a number of issues on the specificities of different situations at various platforms.
As we identified these two dividing lines, it became possible for us to identify four different foundational positions when writing social media policies.
Figure 2: Four different foundational positions when writing social media policies.
Social media is homogeneous and only a problem. We called this the bureaucratic foundation. Policy work is seen as rather straightforward. The main ambition is to extend and adapt existing regulation and create a clear structure for managing and standardizing communications through social media. This was the most common position in our material.
Social media is homogeneous and also as a resource. We named this the branding foundation. These documents tended to highlight the relationship between social media resources and other Web–based resources. With this position, it becomes important to create guidelines that enable more visibility for the municipality and their services. Furthermore, these texts tend to be preoccupied with issues on supplying the same information and service regardless of communication channel. Issues relating to the brand of the municipality are discussed.
Social media is heterogeneous and only a problem. This is the disciplining foundation. It is characteristic of the official guidelines from the E–delegation. The complexity and heterogeneity of social media is seen as a serious problem and as a challenge for the Swedish legislative system. These policies see the adaption of the principle of freedom of access to official records as the main problem to be solved. As this problem contains a high degree of complexity, all other goals, ideas and strategies become secondary.
Social media is heterogeneous and also as a resource. We called this the participatory foundation. Although these texts also were concerned with the adaption to national legislation, social media was also seen as a vehicle for increased participation and democracy. These policy texts also generated many ideas on how social media could be used in order to increase dialogue with citizens and increase the quality of services.
3.2. Social media policy challenges
We identified a large number of policy problems. As already have become evident, the foremost of these relates to the adaption of the traditional Swedish legislative framework. This is a main focus in all of the documents. One feature that took us by surprise was the overall absence of seeing the definition of social media as a problem. Most texts stipulated a general definition of social media and none of the texts reviewed recognized any problems in making that kind of definition. However, definitions varied widely and we have already noted that social media basically was seen as either heterogeneous or homogeneous. A standard phrase, that was favored within several of the heterogeneous viewpoints, was along the lines of “social media can be defined as activities that combine technology, social interaction and user generated content”. Still, despite recognition of the complexity of the concept social media, definition was not seen as a problem. Those that viewed social media as heterogeneous tended to emphasize the diversity of specific social media, often by reviewing the most popular applications, such as Facebook, YouTube and Twitter. These policy texts, as a consequence, tended to discover and discuss a number of specific problems relating to the various social media. Often, these specific problems, although promptly dealt with, carried underlining sub problems that constituted a challenge to the whole frame of the policy. These aspects were not addressed, but they will be focused in the analysis of this article.
In taking inventory of problems, we realized that most of those discussed in the various texts could be placed under a common heading: command and control. Once again, as many policy texts obsessed about this theme, issues relating to public participation become secondary. The following is a list of some of the policy problems that dominated the texts that we reviewed.
Table 2: Dominant policy problems. What are we doing and how can we know what we are doing? How can we control our activities from the top down? How can we know what people are saying about us and how should we react to that? Which users are permitted to use social media & how should such permission be given? How should social media activity be initiated, maintained & finalized? How should social media activity be documented and evaluated? How fast and with what delegation should we respond to questions posted in social media? How should different social media activities be connected to each other and to other Internet resources?
Alongside this heavy focus on command–and–control issues, we also found one problem that was both expected and unexpected: what is the purpose of municipal social media activities?
We were surprised at the level at which this question was discussed. The overall tendency was that when this question was posed at the overreaching level, it was passed upon. In other words, each social media activity should be required to uphold its own purpose. We had anticipated a general–purpose connected to democracy and citizenship participation. Instead, we found this as one of many possibilities outlined in documents.
The outcome of this kind of positioning is that adherence to regulation becomes primary and purposes relating to democracy become secondary. This is most clearly specified in the guidelines of the E–delegationen (2010). It is stated that there can be many purposes underlying social media activities, such as :
- increasing access to the authority;
- disseminating to more citizens and corporations;
- crowd sourcing and feedback;
- improving relations with citizens and corporations;
- increasing credibility with citizens and corporations;
- reaching groups that are difficult to access with other channels;
- reaching specific groups;
- compensating for other channels;
- environmental scanning; and,
- reducing costs.
It is here recommended that the authority selects the most appropriate social media activity for the purpose. However, they also, quite crucially, stipulate that the authority should produce a rational model for the activity that strictly adheres to the stipulated purpose. Furthermore, the activity should be steered so that the activity stays close to the purpose, the demands of the organization and legal demands. To this, it is added: “If this is not attainable the authority should abstain from social media engagement.” 
We read this as “better safe than sorry”. It seems to be an expressed prohibition of working with social media in any kind of experimental fashion. Furthermore, it is, implicitly, stipulated that citizens cannot contribute to decisions on the purpose of social media activities.
3.3. Strategies to address challenges
In the following, we will briefly discuss strategies relating to the overreaching problem of how to discipline social media in line with legal requirements. We will thereafter more in detail discuss specific strategies relating to the problem of command and control. We will close our empirical review by identifying and analyzing four different strategies that became visible in the policy documents with a participatory foundation.
3.3.1. The strategy for disciplining social media
Much text was devoted toward the specific problems of adhering to the principle of freedom of access to official records. We did not find much disagreement on how to proceed. The strategy was quite simply to attend to details. The task of converting freewheeling social media practices into bureaucratic procedure required discussions and decisions on a number of specific issues. These are worthy and important discussions, many of them philosophical in character. However, the end result is a system of restrictions that actually serves to take the very spirit out of social media interaction. We found detailed discussions on:
- How to document activities.
- How to make documents available.
- How to know when a document is seen as created.
- How to know when a document is revised/updated.
- How to know when the document has found its final form.
- Differences between publication on the Web site, paper and social media.
- How to delegate responsibility for writing, revising and publishing texts.
- How to educate civil servants on social media and legal requirements.
- How private and work related content should be related.
- How backups should be made.
- How documents were to be deleted.
- How work time were to be allocated.
- What the tone should be used in replying to queries.
- How “overlapping activities” should be avoided.
- How publication of “unstructured material” should be dealt with.
It seems to us that many of these detailed guidelines are grounded in a frantic attempt to make social media interaction look like paper–based communication. These were, indeed, the basic ideas of the command and control principle. Paper was printed, thereby fixated, and then disseminated. Digital Web based information is not like that at all. It is open ended, often embellished with tags or links. Authorship is frequently uncertain and the possibility of revising and updating is actually mostly an advantage, not a problem. In short, Web–based information is flexible and slippery. Strategies of making it look like paper will encounter severe difficulties.
3.3.2. Strategies for command and control
Most writers of policies seem to have been concerned with finding and stipulating a formal system for command and control. From our perspective, much of this can be seen as counterproductive given the character of social media as resources that develop according to their own trajectories as well as the insidious mingling of formal and informal topics and styles. Nevertheless, the system for command–and–control is the backbone of most policies. Furthermore, in this area, there is a surprising degree of agreement on how things should be done. All decisions on initiating an activity within social media must be taken either by mid–level leadership or at the very top. All activities should be fed into the information unit, which maintains “the list” on all social media activities. There should also be a clear allocation of responsibility to certain civil servants. Comments should be responded to quickly. All this seems rather straightforward. However, some of the policies deal with specific issues concerning command–and–control and on that level, there is a surprisingly little repetition, i.e., different distinct problems are recognized by different policies.
We will, below, briefly touch on some of the issues relating to command–and–control that appear in various policies. Usually, these implicitly, but not explicitly, deal with the fundamental difference between digital Web–based social media and traditional print–based command structure. One fundamental difference is, of course, that Web–based information is much more difficult to control. For instance, it can, and often will be, revised and updated. While paper–based policy communication often is an integrated part of the exercise of power, official involvement with digital web publication/communication tends to undermine hierarchical systems of power.
Relationship to homepage
eyond the mandatory idea of a list maintained by the information unit, most policies aim for other types of connections with the municipal homepage. This is, in our reading, a strange notion of “social media on a leash” and it actually constitutes a serious dilemma. This strategy is most visible in policies with a branding foundation. By clearly linking social media content to the official character of the homepage, the municipality is creating more of an official sanction to everything that happens on any of these social media relating to the municipality. Furthermore, as most relevant social media are U.S.–based business models, there are obvious ideological difficulties. At the extreme end, in one policy it is maintained that all content, with the exception of Facebook, should be able to be aggregated to the main home page through RSS or JSON.
There is a similar problem involved in the suggestion, proposed by several municipalities, that the graphic profile of the homepage should be used in various social media as well. Only one of the policies addressed this issue differently, stating that most social media disallows that kind of graphic control. The graphic profile should therefore not be used according to this policy.
One issue almost always addressed, concerned if the blogs of politicians should have links on the municipality homepage. All those that dealt with this issue came to the same conclusion: yes, this should be allowed, but it should also be clearly stated that these do not represent the official views of the municipality.
Previous Web policy
Several policies reproduce existing policies on Internet and e–mail use, suggesting that these are equally valid for social media. There is an implicit problem suggested by this procedure: what is the relation between social media policy and other policies relating to the Internet? Obviously, various policies are taken to be congruent with each other. This is also the reason why main legislative texts actually are helpful for the municipality policy work. If all of them connect symmetrically to the same legislative framework, then they should by necessity be congruent with each other. However, this is false logic since different policy areas quite simply require specific policy interpretation. More concretely, previous Web policy tends to be marked by regulation of Web 1.0, which is similar to traditional modes of administrating paper. Social media builds, instead, on the technologies of Web 2.0. Extending the older policy to social media activities is therefore problematic.
The professional and the private role
The strict separation between the professional and private role is a major focus in almost all policies investigated. There is, also, quite broad agreement on how to address this issue. Any communication from the civil servant working with a mandate to operate an activity should at all times be clear on this being a professional response and not something said by the same person in private. Although there is such a fundamental agreement on this issue, it is deeply problematic. This policy prescribes a model where citizens are likely to meet a person whom they cannot engage in constructive debate. The professional is obliged to speak everything by the book. Since conversations in many social media are documented, it also becomes obvious to those evaluating or involved in legal strife if the civil servant in any way have slipped from the professional role. This would make the official social media response more formal than a traditional telephone call, which is not documented. On the phone, it becomes easier for the civil servant to say, “privately, I can sympathize with your situation”.
An interesting suggestion in one policy text is that it can be possible for the civil servant to switch between a professional and private role. In that case, the former is suggested by including the official position and address. The strictly professional role actually strips the professional from much of the interactive potential of social media. With a less formal approach, the professional is able to be more receptive and respond to situations that are slightly beside the actual intentions of the political procedure of the municipality.
Delegation of response
As questions or comments on social media can concern any policy area, it is unlikely that the person responsible for administrating an activity would be able to adequately respond to all of them. Several policies discuss this problem and they also suggest the same remedy: delegation of response. There is, nevertheless, a kind of dilemma tied to this policy. Several texts within the broader strategy emphasized that separate social media should be administrated in different ways. Also, there were at times different policy ideas and regulations connected to distinct applications. In addition, a few policies emphasized that civil servants needed to be educated on how to deal with various social media as well as on policy guidelines and relevant national legislation. In other words, these, quite valid, ideas suggest that sophisticated administration of a social media activity requires civil servants that have been well trained for their task. However, the requirement to delegate responses to specialists within the municipality tends to undermine this approach. The dilemma is, then, that responses will either be from someone specialized on working with social media or on one specializing in the topic related to the query.
This dilemma is born out of the controlling mode of policy. It would seem to be more natural that specialists are responsible for their own social media activities and they can therefore uphold both competencies.
When policy text deals with the seemingly problematic issue of “overlapping activities”. This is a problem akin to the ones relating to the professional role and that of delegation. It can be noted that it is quite possible that the same person poses the same question through different social media. All questions are to be responded to. However as, for example, discriminatory questions may be ignored or removed; it is quite possible for an individual to politely bring the administration to its knees through a sabotaging strategy. The problem of overlapping activities can be solved by strict delegation. However, as we have discussed, the principle of delegation has its own problems. In essence, controlling overlapping activities and responses seem to be very difficult.
The activity plan: Furthering rational decision–making
Several policies have concrete suggestions for how work with social media can be more effective. One of these is the “activity plan” which is to underpin the decision to initiate social media presence. Although such an idea is vaguely implied by most policies, only one text is more fully concerned with the details of such a plan. First, it is suggested that concrete and measurable goals are stipulated. Second, these are measured over time. Indicators can be, number of comments/questions, number of responses, number of visitors, number of friends, etc. Finally, these indicators are used in order to evaluate specific activities. Following this, the activities are either revised for further improvement or shut down.
Although this suggestion only reflects one municipality, it is likely that similar ideas are simmering in most of the others. Several do approach the question of evaluation and one of them argues that a passive social media activity is simply bad PR and should be shut down.
The larger issue is, of course, which kinds of goals are involved and which are possible to work with in various social media? And, furthermore, by which criteria activities should these be evaluated?
Most policies emphasized that it is important that there is a clear purpose underpinning all social media activities. From our perspective, there are two problems in the way this kind of discussion frames policy work. First, this fundamentally remixes priorities as one avoids pointing to an overreaching purpose: democracy and participation. Second, there is a dilemma in prescribing and fixating a clear purpose for social media activity as this is something that, at least in part, should be developed in interaction with the citizens.
The problem with prescribing distinct (and single) purposes becomes quite clear when one takes an inventory of the many possible purposes for municipal social media activity. Our work with taking an inventory was alleviated by an actual list of 18 purposes included in one social media policy:
- complement to traditional Web sites;
- disseminating information;
- testing new forms of reaching target groups;
- reaching target groups that otherwise are not reached;
- engage with target groups;
- receiving input;
- improving service to target groups;
- creating dialogue;
- attracting and recruiting new civil servants;
- create goodwill;
- strengthen brand;
- exchanging experiences;
- environmental scanning;
- aggregate traffic to municipality Web site;
- be able to respond to that which is written about us; and,
- improve access.
Although one could argue that there were some overlaps in this list, it tends to demonstrate the diversity of possible purposes. All these seem to be worthy ambitions. However, if we are to follow the consensus of these policies, individual social media initiatives should be connected to different purposes. This also unveils the complexity of social media administration and the difficulty of the controlling paradigm so evident in these policies.
3.3.3. Participation strategies
We will here review four different strategies that build on ideas that, at least in some measure, either on a participatory or a branding foundation.
Several municipalities attempt flexible guidelines in which the civil servant should be allowed to exercise sound judgment in relation to contextual issues. Different factors are emphasized in various policies and quite often several contextual aspects are discussed. In practice, it is argued that general and simplified rules become difficult, as a suitable response is dependent on:
- type of social media;
- type of communication;
- character of target group;
- character of language;
- type of message; and,
- purpose of the interaction
The basic idea of this kind of adaptive strategy is to formulate fewer general rules that, in addition, are more flexible. However, several municipalities fail to recognize that there is an inherent conflict between heavy top–down restrictions and bottom–up allowance. These policies are therefore fundamentally incongruent.
This positioning in relation to an adaptive strategy goes to the heart of the research interest in this article. We argue that a strong and restrictive top–down approach is incommensurable with an adaptive strategy that allows civil servants to be case sensitive. You cannot both build strong command and control and empowered civil servants. There is no comprehensive middle ground. Furthermore, separate difficulties are associated with choosing one or the other of these alternatives.
Two citizenship strategies
There lies a substantial potential in utilizing social media for interaction with the citizens of the municipality and this is emphasized in several policy documents. We found two basic variations of the citizenship strategy and the different emphasis on these goes to the heart of our argument in this study. The first, here named the transparent citizenship strategy, aims to further the traditional values of freedom of information access. Keywords for this strategy are: increased access, openness and transparency. To put it bluntly, this strategy is aimed at creating an open government where we can clearly see that “everything is done by the book”.
The second, here called the interactive citizenship strategy, emphasizes social media as an instrument for generating feedback. This, in turn, becomes valuable in processes of increasing the quality of services. With this perspective, interaction, not transparency becomes primary.
From our perspective, there is a contradiction between these two citizenship strategies. If we are concerned about showing everybody that we are doing things by the book, our interactive skills will without fail suffer.
Interestingly enough, we find that the ideals of transparency can be connected with commercial values. Within policies with a branding foundation, it is sometimes argued that social media can be utilized in order to strengthen community brands. This idea is then underpinned by an image of administrative units, which actually are listening and responding to the needs of the citizens. However, many policy documents are just as worried about social media being damaging to the brand. What happens if we increase transparency and it is found that we are not doing things by the book? This is, actually, a major concern in most of the documents we have reviewed. There seems to be a widespread fear that social media activities can fundamentally damage brand values if not performed with a high degree of professionalism.
Another quite common angle is to envision social media as a tool for marketing. We have found two variations of this notion and, once again, it is possible to discern different foundational positions behind them. First, there is a marketing effect in social media simply by seeing this as another channel for reaching new target groups. This strategy builds on the branding foundation.
Second, marketing is sometimes seen as a function of interaction. In other words, by exploiting the potential of feedback, we can become better at marketing our services and increasing tourism. Social media is here seen as a tool for environmental scanning. This strategy is more related to a participatory foundation.
In both of these marketing strategies, social media is seen as a resource. Still, there is a mile between them. The first one starts with a message and then aims to communicate it as efficiently as possible. The second upholds an ideal of instead listening for an interesting message. In this case, the citizens become empowered and allowed the opportunity to contribute to better community services. And it is really these, improved services, which become the actual marketing message.
Crisis communication strategy
It is common in these documents to connect to the problem of crisis communication. It is probably of importance that these policies are written at a time when the role that social media played in the earthquake catastrophes of Haiti (January 2010), Chile (February 2010) and China (April 2010) had been quite visible. Although many policies seem to be hesitant about allocating a formal role for social media in a situation of crisis, some documents actually outline two separate roles. These are similar to the distinction made in relation to marketing strategies above.
The first of these is to disseminate news and policy positions. Social media is here taken to be yet another channel as a complement to the traditional TV, radio and newspapers. However, it is sometimes additionally argued that social media is necessary to reach groups that are solely reliant on digital media.
The second role of social media in a crisis situation is to be an instrument of environmental scanning. Social media could, with this perspective, be useful in understanding how the citizens were reacting to the actual crisis. For instance, it would be easier to monitor how the event was developing and in identifying patterns of citizen reaction to crisis.
We find crisis communication to be highly interesting in the context of our discussion. Experiences from the catastrophes mentioned above make it quite clear that social media can be a lifesaver. Interesting efforts have also been made in this area (Moynihan, 2009; Heverin and Zach, 2010; Kavanaugh, et al., 2010; Krakovsky, 2010; Sutton, 2010). However, if the municipality rescue efforts are to be bound by the kind of disciplining strategies that we have found in our policy review, then there is a risk that crisis management through social media will be hampered. Put bluntly, procedural regulation may be given priority over the saving of lives.
It is apparent from the policy documents that the focus of adoption of social media in the administration of municipalities lies firmly in the attempt to have this new technology to existing standards of administrative practices. This approach to social media, however, leads to a large–scale exclusion of the potential participatory effects of the technology.
If the goal is to adapt social media to older regulation, then these are worthy efforts. However, at the end of the day it is our evaluation that such an ambition is doomed to failure. We have showed that the legal texts that are relevant in the Swedish context have ancient roots. Some of the basic ideas come from the eighteenth century, others from the early twentieth century. These legislative efforts were drawn up before the Internet, in most cases before the World Wide Web and certainly without the potentials of social media in mind.
Among the issues brought up we have seen discussions on the concern with linking outside the municipal home pages (illustrated in earlier sections of this paper). While the home page is a relative recent innovation they maintain close links to analog forms of communication. Therefore, external links can have disclaimers that the reader wishing to follow a hyperlink will be moving beyond the domain of control of the municipality. However, such disclaimers are often impractical or impossible in social media situations.
The latter problem demonstrates a desire to view new technology in the light of earlier technology and is reflected in many of the policies. However, this attitude fails to fully comprehend the social media infrastructure. Social media is not just an improvement of an existing technology but it is a break from other communications. It is a medium that changes the ways in which communication occurs. It is a situation where, as McLuhan (1964) famously posited, the medium is the message.
Our study has shown that the natural starting point in regulating social media has been to adapt to several co–existing regulatory elements. Social media policy then becomes an attempt to control users behavior while balancing the fundamental rights of the individual to access information, communicate and participate in the social dialog.
Once the context has been established the social media policy may be approached and, in this, the organization is left with a wide range of choices on the ways in which they may attempt to regulate their employees’ uses of social media. As there are so many choices relating to various regulatory traditions, there is a tendency to get stuck in the complex task of balancing regulatory elements. We have argued that policy regulation need to take account of the regulative power inscribed in the technological artifact itself. The artifact, together with the regulative system, can be seen as a technological system. As the restrictions and affordances of the technological artifact tend to flatten traditional hierarchies of regulation, different rights and obligations are pitted against each other in new and original ways. Figure 1, above, illustrates the complexity of balancing regulatory elements.
The complexity of this balancing act is particularly visible in the attempt to resolve the issue of employees’ public and private roles within the framework of a social media communications infrastructure where the policies show an overwhelming desire to simplify reality by assuming both that private and public persona are static rather than fluid and that one policy may be created that can answer to all the various roles of the municipal employees.
Perhaps the area were the greatest conflict exists is the conflict between the practice and purpose of administration within a democracy. While the social media infrastructure increases the ability of a greater participation in local democracy the focus of the policy documents is increasingly on the preservation of administrative routines.
The affordances of a full, unregulated access to social media provide an incredible potential for supporting and increasing high levels of participatory democracy on all levels of government. However, as the concerns brought up by the E–delegationen (2010) and the municipal policies show, social media also provides many new challenges to accepted administrative practices. These practices, established over the past centuries, consist of laws, policies and routines firmly set in an analogue information infrastructure and are, in parts, incompatible with the communications infrastructure available today.
While the choice to close off, in essence to ignore, technological reality may seem tempting in order to preserve the administrative tradition it is a choice also to ignore the potential democratic benefits inherent to social media. It is also important not to lose sight of the fact that the purpose of government administration is to serve the democratic ideal and not vice versa. Therefore many municipalities are faced with the dilemma of regulation.
It is also vital to remember that the technology not only provides potential benefits (affordances) but also carries with it limitations, biases and alternative ideologies to the democratic ideal. For example most social media is provided not for a higher ideological or democratic ideal but are an integral part of a corporate business model and therefore should not be viewed as neutral technologies. This latter point, while important, is beyond the scope of the present paper.
Figure 3: Policy and technological regulators.
One important challenge to the policy drafter is to balance the right to free speech and duty of loyalty. It has become clear to us during this study that both these traditional features have been put under greater duress with social media.
Therefore, within the organization the choice is to have a wide span of regulatory measures from the seemingly unregulated to the regulated. The popular conception that social media is unregulated is actually, from our viewpoint, an illusion. The absence of a specific policy means that practice is governed by the restrictions and affordances of the technology together with social conventions of unwritten rules.
In most organizations the rules of conduct may consist of sets of unwritten rules, i.e., unexpressed rules that the regulated assimilates through his or her context and follows to a large extent in order not to face social sanctions. The next level of rules is the policy. This document may contain guidelines and best practices in addition to a set of specific or general rules. The final subsets of rules are written rules describing behavior that is prohibited (see Figure 3).
Therefore, it is easy to understand that a wide range of regulators may compromise the potential benefits seen in any technology and the perceived advantages may be easily lost.
We have all through this text argued that the potential of public participation through social media becomes a secondary concern in the focus of appropriate regulative ideas. Social media has been seen as unregulated, guided by unwritten rules. As this, actually, is a setting, which stimulates to participation, the drive to create regulation and prohibition tends to weaken participation.
Paradoxically, most of the foundational regulatory ideas are aimed at stimulating democracy and participation. However, most of the involved legislative texts were formulated at another time. The emphasis has been on open and transparent government. When these regulatory measures are adapted to social media, the actual effect becomes to disempower the citizens. What actually happens is that requirements connected to transparency overwhelm the potential for interaction. With the evolution of exciting social media, interaction is a much better ideal compared to transparency.
Social media carries with it an incredible potential for user interaction with formal regulatory systems. The versatility of the technology will therefore provide a huge number of possible beneficial uses within all levels of governmental activity. However, the technology also brings with it a disruptive effect in that it challenges established information infrastructures and the administrative routines that have been built around such infrastructures.
With a growing widespread adoption of social media in society many branches of municipal activity have been among the early adopters and this use has led to a need for a rule–based clarification on the role, use and position of social media within governmental communication. In this paper we have analyzed the attempts of 26 local municipalities to come to terms with the technology by subsuming it into existing structures through policy documents.
As we have seen the focus of these policies has been to discipline social media based on an analog world view where the basis for control is enacted through a system of command–and–control type regulation. This approach has led to a hobbled social media where many of the main advantages are lost. Many municipalities have attempted to go beyond a limited understanding of regulation by intuitively adopting a wider concept of regulation and taken into consideration a broad range of factors such as licenses, affordances and social norms. The latter is a more nuanced regulatory approach that demonstrates a more sophisticated comprehension of the digital environment. It is less compatible with entrenched regulatory systems. Among the municipalities attempting to address these issues we have identified different separate strategies, yet in general, there is a strong desire towards preserving the status quo in administrative systems that makes adopting pro-social media policies challenging for local government.
To be able to fulfill the potentials of social media in participatory democracies it is important to understand that enforcing a paper–based analog system on to what is arguably a digital speech based world is bound to fail.
As a result we see that among the Swedish municipalities we have studied the consequence of policy remains biased towards analog systems, which has the effect of cancelling much of the potential effects of social media in government.
About the authors
Mathias Klang, Ph.D., currently works as a researcher and senior lecturer at the Universities of Borås & Göteborg. His research is in the field of legal informatics with particular interest in copyright, online expression, digital rights and regulation. He is currently researching these areas in relation to social media. Among his work is a co–edited volume (with Andrew Murray) entitled “Human rights in the digital age” and his Ph.D. thesis “Disruptive technology: Effects of technology regulation on democracy”. In addition to this Mathias is the Project Lead for Creative Commons Sweden, blogs at digital–rights.net and twitters under the alias @klang67.
E–mail: Mathias [dot] Klang [at] hb [dot] se
Jan Nolin took his Ph.D. in theory of science and is currently professor at the Swedish School of Library and Information Science. His main research interest lies in the coproduction of Internet technology and society.
E–mail: Jan [dot] Nolin [at] hb [dot] se
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Received 15 March 2011; accepted 6 July 2011.
This work is licensed under a Creative Commons Attribution–NonCommercial 3.0 Unported License.
Disciplining social media: An analysis of social media policies in 26 Swedish municipalities
by Mathias Klang and Jan Nolin.
First Monday, Volume 16, Number 8 - 1 August 2011
A Great Cities Initiative of the University of Illinois at Chicago University Library.
© First Monday, 1995-2017. ISSN 1396-0466.