Social networking and Verifile policy statement (Part 4)
Conduct, social media and networking statement
We look forward to welcoming you to your role with COPFS and would like to take this opportunity to provide you with guidance regarding our Social Networking Policy and our Conduct Outside Normal Working Hours Policy.
Whilst acknowledging that a balance between work life and personal life is required, as future Civil Servants in public office, you must remember at all times that your conduct impacts on the perception and reputation of COPFS and you should not act in a manner that presents a negative image of the organisation.
As such, we would expect you to consider your conduct in private affairs to reflect a manner which does not leave COPFS exposed to compromise or corruption, or which may bring the service into disrepute were those actions to be brought to public attention. This also includes the way we behave when engaging in online professional and social networking.
It is advised therefore, that all future employees personally risk-assess their position before creating any personal profiles and should not seek to publish or exhibit anything, textual or photographic, that would affront, insult, or detract from, the dignity of their future public office, their personal integrity, or the integrity of the Crown Office and Procurator Fiscal Service, given that all such information is appearing in the public domain. You are further advised not to disclose anywhere in a personal profile anything which indicates that you are employed or will be employed in this organisation.
COPFS may consider withdrawing offers of employment where it comes to our attention that a future employee’s conduct outside working hours has the potential to bring, or has actually brought, the Service into disrepute.
Introduction
Crown Office and Procurator Fiscal Service will routinely carry out BPSS (Baseline Personnel Security Standards) checks on all new entrants which must be cleared as a condition of the employment offer. As of October 2024, pre-recruitment checking will include OSINT (Open-source intelligence) checks on publicly accessible social media content.
The purpose of these checks is to ensure all potential COPFS employees are subject to contemporary vetting measures that will support the assessment of suitability for appointment to positions of trust.
Current check provider
The current social media checking contract is held by Verifile.
How reports will be used
Where a social media report is returned with no adverse flags the HR Resource team will advise candidates that this check has been cleared.
If a report is returned with adverse flags highlighted the HR Resource team will treat this as a ‘doubt’ and each element will be considered on a case-by-case basis.
Consideration of any ‘doubt’ raised will be given by the HR Resource team in the first instance and only shared wider where input from appropriate colleagues is relevant. Any detail provided as part of this process will be treated in line with the privacy notice for job applicants.
When considering a ‘doubt’ the nature of the role offered, Civil Service Code, COPFS values and relevant dates will be taken into account to determine if there is evidence of behaviour that is incompatible with the role or indicates a conflict of interest.
Where such evidence is acknowledged the candidate may be provided with specific elements of the report and advised that the finding has been determined as incompatible with the role. This would result in the check not being cleared and the conditions of the offer not met. There will be no right to appeal this decision.
Not all adverse flags will be determined as incompatible with the role. In some instances, the HR Resource team may determine that although there is no incompatibility it may be relevant to share elements of the ‘clear’ report on the basis the candidate is advised of what has flagged and is provided with a copy the COPFS Social Media policy or other relevant COPFS policy
We will not retain any paper or electronic reports. We will, however, record the date the report was requested and issued, the case ID and details of our decision. The same conditions relating to secure storage and access apply irrespective of the period of retention.
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Social media check process
As part of the normal pre-recruitment checks a search of publicly accessible social media use is carried out by Verifile using ONSIT. Open-source intelligence (OSINT) is the collection and analysis of data gathered from open sources (covert sources and publicly available information; PAI) to produce actionable intelligence. The results of checks will be considered against the Civil Service Code of Conduct, COPFS values and nature of the role to identify incompatible behaviour and potential conflicts of interest.
The checks carried out will identify the following categories of social media content;
Where content within these categories is flagged to us COPFS will consider the details and date of occurrence in line with our COPFS values and nature of work on a case-by-case basis.
For information on social media privacy controls and safe use visit the National Cyber Security Centre website.
Following acceptance of a conditional job offer candidates will be directed to provide basic information to Verifile, the checking service. This will return a report to the COPFS HR Resource team. Manual consideration will be given to each report.