Consultation response on proposed guidance for communicating online

Introduction

Communicating with people is at the heart of social work. In recent years, there has been huge growth in the number of ways we can communicate online. For social workers, this has meant new opportunities to communicate with the people they support in ways that meet their needs and expectations. It also enables them to connect easily with colleagues, to share knowledge and collaborate on cases. But it has also created challenges around understanding these new technologies and how they can be used appropriately while maintaining professional boundaries and standards.

In August 2025 we launched a 10-week public consultation seeking feedback on 2 pieces of proposed guidance to help social workers navigate these challenges:

• Communicating online guidance for social workers, which sets out how social workers should apply the professional standards when they are communicating online; and
• Communicating online guidance for decision makers, which sets out what our decision makers will consider when a concern is raised with us about a social worker that relates to their online communication.

Guidance for social workers

We intend the guidance for social workers to help them apply the professional standards when they communicate online. Within the guidance, we set out 4 general principles that social workers should consider:

• Security
• Accountability
• Using the right tools
• Maintaining boundaries

The guidance shows which professional standards are most relevant when communicating online. It also gives an outline of how we would consider a concern relating to a social worker’s online communication, which is set out in more detail in the decision maker’s guidance.

Guidance for decision makers

We developed the guidance for decision makers to help them consider concerns about a social worker’s online communication. It will ensure that they consider all the evidence available, and act consistently. Decision makers include (all of the following): 

• triage staff 
• case examiners
• adjudicators 

How we consulted

We are committed to making sure our work is informed by everyone who has an interest in social work. We believe in the power of collaboration and co-production, which is why we consult on proposals that may impact those who use social work services, the social work profession, and the wider social work sector.

We wanted to hear from those who might be impacted by any proposed changes. To enable this, we shared the 2 pieces of proposed guidance and an explanation of what they were for on our website and promoted the consultation through our communication channels.

We asked respondents to provide their feedback by (either of the following): 

• completing a consultation survey made available on our website
• emailing our consultation email address directly.

We recorded, read and analysed all the responses. As well as producing data on how many responses thought the proposed guidance was clear or not clear, we recorded the themes in the free text responses and noted key suggestions made by respondents.

Who responded?

We received 30 responses to the consultation:

• 21 social workers
• 2 people with lived experience of social work
• 2 on behalf of organisations (1 trade union and 1 advocacy group), and 5 others. 

What you said

In the survey, we asked people to tell us how strongly they agreed or disagreed with a set of statements. They could rank their level of agreement on a scale from ‘strongly disagree’ to ‘strongly agree’. The scale helped us to understand the extent to which people supported or opposed our proposals. We then asked respondents to give reasons for their answers. Below is an overview of what people told us. 

Statement 1: The guidance and language used is clear and easy to understand.
70% of respondents agreed that the proposed guidance was clear and easy to understand. Feedback from those who disagreed (13.3%) included that the guidance was overly ‘general’ or ‘broad’ and that some of the terminology and definitions used could be at risk of being too vague. For example, UNISON felt that ‘lack of detail and definition risks being exposed […W]hat counts as offensive content and legitimate debate remains vague’.

Statement 2: The guidance will be helpful for social workers in upholding the professional standards when communicating online.
60% of respondents agreed that the proposed social workers’ guidance would help them to uphold the professional standards when communicating online. 
26.7% disagreed and a number of those responses suggested that examples and more detail would make the guidance more useful.
“[C]ommunication is a 2 way or multi way process. The guidance] does not cover when social workers Google and or contact clients on social media” (Anonymous respondent)
UNISON also recommended further clarity on balancing social workers’ obligations to adhere to the professional standards with their lawful freedom of expression.

Statement 3: The guidance is relevant to current social work practice.
70% of respondents agreed that the proposed guidance for social workers was relevant to current social work practice. Respondents who agreed with this statement fed back that the guidance makes it very clear that social workers are responsible for their online communication, contained helpful information about checking privacy settings, and was practical.

“It is very important as a Social Worker to ensure that all communication, whether at work or within my private life does not have any links to violence, racism or disability in a negative way. As a professional you are responsible for everything you say, do or post. This guidance makes this very clear.” (Social worker, adults)

“[V]ery clear well worded guidance linking in with the required standards and competencies in each section […] There was also really helpful information about privacy setting[s] and a reminder to check.” (Social worker, children & families)

16.7% disagreed that the guidance reflected current practice. Several respondents felt that certain types of online communication on specific platforms should be specifically referenced in the guidance. The types of communication suggested included online communication with service users and, more specifically the importance of boundaries and appropriate documentation of such communications. Another aspect of social media communication mentioned was the need for the guidance to cover the need for social workers to look more closely at their past social media activity. 

UNISON fed back that further guidance should be included to address the risks posed by certain platforms, such as dating apps and LinkedIn. It was suggested that further detail around use of LinkedIn would be particularly useful as it is found to encourage a crossover between social workers’ personal and professional lives. 

Statement 4: The guidance for decision makers accurately reflects the expectations set out in the guidance for social workers, and it is clear how the two pieces of guidance are related.
63.3% of respondents broadly agreed that the proposed guidance for decision makers accurately reflects the expectations set out in the proposed guidance for social workers, and that it is clear how the 2 pieces of guidance are related. 

People who disagreed with this statement (16.7%) were concerned about previous online communications, and felt that there was insufficient clarity about why previous communications would be relevant in any new concern, or about how decision makers would consider its relevance.  

“The guidance says that an investigation can go back to any point in time, in relation to any concern at all, including outside of the workplace. This is surely far too vague? […] What constitutes acceptable/[understandable] behaviour in one situation but not in another?” (Anonymous respondent)

Other feedback 
We also received additional feedback that that wasn’t directly in response to one of the questions, or which fell outside the scope of this consultation. Much of this feedback related to broader concerns about the potential impact of the introduction of the 2 pieces of guidance on social workers’ right to privacy, freedom of expression or freedom of speech. Several respondents raised concerns that the implementation of the guidance could impede a social workers freedom of speech or expression. A small number also made specific reference to the case of Ms R Meade v Westminster City Council and Social Work England in relation to the importance of being able to maintain freedom of speech.

What we will do

We read all the responses that we received, and have carefully considered whether we should make any changes to our proposed guidance as a result of what people have told us.

Examples or application to specific platforms

A number of respondents asked us to consider giving examples of how the guidance applies to specific tools or platforms in the guidance for social workers, or to give specific advice about communication relating to certain topics.

However, we have opted not to name any tools or platforms, like Google, Facebook, X, LinkedIn, Instagram or WhatsApp. This is because:

• our guidance is intended to help social workers apply the principles of the professional standards to all instances of communicating online and is not more or less relevant to any particular tools or platforms. 
• the names of these tools or platforms, and how they work, can and does change. New tools and platforms also emerge.
• by focusing on, or naming, some tools or platforms, we might make it harder to understand how the principles in this guidance apply to other, potentially very different, tools or platforms. The guidance applies as much to the use of individual local case management or communications systems as large-scale popular social media apps. 

In relation to topics, it would not be appropriate for us to give guidance on what is and is not appropriate to say. The guidance sets out our expectations for how social workers will apply the principles of the professional standards when they are communicating online on any topic. These principles can apply regardless of the specific views or opinions being communicated. They also apply where no opinion is being expressed. The guidance also sets out what decision makers will look at when they are investigating concerns in any case that is referred to us.
 
For these reasons, we have not included specific examples of tools or topics. While we have not included specific examples in the guidance, we will look for opportunities to create supporting information, which we would make available alongside this guidance on our website. 

Concerns about previous or historic posts

We understand that some of our respondents felt that previous or historic online communications should not be considered relevant to any concerns raised about a social worker today. 

Our role is not to police past communications, but to take account of all the relevant evidence about a social worker’s fitness to practise, which may include past communications, when a concern is raised. Past posts may be relevant in some circumstances.

Firstly, as the regulator we can consider any concerns raised about a social worker’s practise prior to their registration as a social worker. As such it is possible that a complainant may raise concerns about a social worker’s past online communication. However, in order to progress concerns of this nature for investigation, we need to be satisfied not only that there are reasonable grounds for investigating whether the registered social worker’s fitness to practise is impaired but also that there is public interest in doing so.
 
Secondly, past online communication may be relevant when considering whether contemporaneous posts reflect an attitudinal issue. As above, we’ll look for opportunities to create supporting information which we would make available alongside this guidance on our website.  

However, as we set out in both pieces of guidance, our objective in considering a concern is to determine whether there is a realistic prospect of finding that a social worker’s fitness to practise is impaired. Previous posts or communications can provide evidence about the duration or extent of any conduct that indicates that a social worker’s fitness to practise may be impaired.

We will look at the language we use in our guidance to ensure that we describe as clearly as possible what we will consider and why we think it may be relevant. We’ll also look to clarify that our role is not to police past communications, but to take account of all the relevant evidence about a social worker’s fitness to practise, which may include past communications, when a concern is raised.

Response to ‘other feedback’

While we understand the concerns about the impact on social worker’s rights, the guidance was developed taking into account relevant legislation and case law to ensure that we were striking an appropriate balance between the social worker’s rights and their role as a registered professional. This included reflecting on learning from the Meade case, which we did to inform improvements to our processes including the development of both of these pieces of guidance. As such we are confident that we have appropriately taken into account the legal position in this guidance document. 

We understand that some respondents also called for guidance for social workers in engaging with transgender individuals in their professional practise. However, this falls outside of the scope of this guidance, which is limited to the use of online communication tools. 

Ahead of publishing both the guidance for decision makers, and the guidance for social workers we wanted to deliver training to our decision makers, and FtP teams. This training has now been delivered by an external legal provider to:

• Case Examiners
• Triage and Investigations teams
  1. Adjudicators and legal advisers
  2. In house legal teams 

The training will also be made available to other staff members.
The purpose of the training is to ensure that our FTP staff and in particular decision makers understand, and can apply the guidance for decision making. We felt this was important work to complete before the publication of the guidance externally. 

Equality Impact Assessment

Introduction

We’re committed to monitoring the impact, and enhancing the accessibility and content, of all our services to meet our equality duties and objectives. We’ve reflected on the feedback from our consultation to assess the potential positive and negative impacts of our proposals. This equality impact assessment sits alongside our consultation response. It is a written record that shows how we’ve taken care to eliminate unlawful discrimination, advance equality of opportunity and foster good relations.

Consultation responses

Within the consultation survey we asked respondents whether they thought that following the communicating online guidance could impact any persons with a protected characteristic, and if so, how it would impact them, and whether the impact would be positive or negative. The responses have helped us to understand which groups could be impacted and consider areas for change and improvement.

What you said and what we will do

17 (56.7%) people responded that they thought that following this guidance could impact people with 1 or more protected characteristics, while 12 (40%) could see no likely impact. 

Race
A couple of respondents suggested that the publication of the guidance could result in a negative impact on people from global majority backgrounds. 

However, the extra clarity provided by the guidance may in fact lower the risk of concerns that do not meet the threshold for investigation being raised, including for social workers from global majority backgrounds. Therefore, we believe that the publication of the guidance could have a positive impact based on the protected characteristic of race. We also believe that any potential negative impact is mitigated by the mandatory requirement for our decision makers to undertake training on unconscious bias. 

Age

Several respondents suggested that both younger and older social workers may be disproportionately impacted by the publication of the guidance. 

UNISON suggested that older people may be less comfortable or familiar with online communications tools and platforms and may find it harder to apply the professional standards when using them. 

On the other hand, several respondents felt that younger social workers would be more likely to have a long history of online communications, including as a child and before becoming a registered social worker. With more historic content available online, these social workers could be more vulnerable to complaints about their online communications. 

While we agree that these challenges are present for both older and younger social workers, this guidance provides more detail about applying the professional standards, including reminders to review past posts, and (in the decision makers’ guidance) detailed information about what factors we would take into account if a concern were raised. The guidance is a tool to make communicating online within the professional standards easier. 

Disability

We are also aware that, for many people with disabilities, online tools can be essential, helping them to overcome communications barriers that they face. This means that they may depend more on online communications tools or platforms than others. We think that, in providing more detail about applying the professional standards to communicating online, the guidance could have a positive impact on people with disabilities, giving advice on an area of particular importance to many of them.

Several consultation respondents shared broader views on perceived societal issues that may particularly affect those with certain characteristics. As the purpose of the guidance is to clarify the existing responsibilities of social workers under the professional standards, and would not impose any further responsibilities, the comments received regarding broader issues are not directly relevant to this consultation. 

We do not believe that the guidance will have a negative impact on people with protected characteristics. By clarifying how social workers can apply the professional standards when communicating online using any tool or platform, we believe the guidance will benefit all social workers.

This equality impact assessment has been undertaken and signed off in accordance with Social Work England’s responsibilities under the Public Sector Equality Duty, as set out in the Equality Act 2010.

Name: Philip Hallam
Title: Executive Director, Regulation
Date approved: 4 February 2026