Gov’t FB Pages: Allow Fans to Post or Not?

Here’s a discussion from a gov’t web managers listserv.

The original question was: should gov’t Facebook pages allow people to post?

I want to be very clear: I interpreted this question as being about posts – where they start a whole new item: text, photos, videos, links, etc. I’m emphatically NOT talking about accepting comments. To me, that’s a non-discussion: you absolutely must accept comments, good and bad, in accordance with a published comment policy. For example, EPA’s is here.

In the image, I’m discussing allowing people to use what’s in the red box at the top of the page, not the “comment” link or “write a comment” in the green boxes.

At EPA, we welcome comments on our main page, but don’t allow people to post their own stuff.

There are plenty of places for them to make their points, including commenting on our posts. We don’t need to give them a platform.

I disagree that not allowing them to post is the same thing as any other Web page. Other Web pages don’t allow comments, aren’t shareable, and aren’t in a network of 500 million people.

Plenty of interaction happens without allowing people to put whatever they see fit on your branded page.

I think of it this way: a social media presence is like a booth at a shopping mall. You’re there so they can see you as people vs. an institution, you talk to people, you listen to what they say, they can hear each other’s ideas, and you catch casual conversations among people all around you whether they’re talking directly to you or not. You might even hold a public discussion, where you put out a question and then invite people to share their thoughts.

But you don’t allow people to plaster their posters all over your booth and you don’t hand them the microphone unchecked for 3 hours to say anything on any topic.

What do you think? What does your agency do?

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Adriel Hampton

I agree no. Especially due to the culture of Facebook – almost all posts on other people’s walls appear to be spam.

Brett White

Personally, I’d love to jump in feet first with a completely open Facebook page where fans contributed alongside our agency (a municipality). But that’s only in a perfect world where our constituency was made up of polite and cordial happy-bots. Last time I checked…that’s not reality. And since our main purpose is to engage the public in discussions over information that we release, we’re going to stick with just the comments and “likes”.

I know…we’re wusses. 🙁

Eric Erickson

I manage the Facebook wall for the IRS Recruitment Office — I also responded to that ListServ — We have had tremendous success with our page. We allow people to post original comments, as well as likes and responses. We have seen some spam, but it’s minimal — we’ve found the more we manage our page and remove junk, the less we see. Spammers seem to be getting the message that we do not tolerate it. We have very specific guildelines for what people can and cannot post. Those guidelines are very clear, and the vast majority of our fans comply.

Jeffrey Levy

Eric: help me understand your policy (and also, can you email it to me?)

What would you do if someone posted 5 times/day to say that IRS is stealing taxpayers’ money?

What would you do if someone posted 25 times/day to say that they disagreed with how IRS did its hiring?

In other words, if it was on topic but overwhelming, what would you do?


Dannielle Blumenthal

Speaking for myself and not my agency of course, I agree with Eric. Let them comment freely and take down the spam.

Think about it from the customers’ point of view. The whole fun, the whole point of FB and social media is the ability to comment and interact. (Gov is always so afraid that people hate us…because they actually do hate us…because they don’t know us at all.)

If you don’t allow comments it’s just one-way communication that abuses the medium.

How to handle the stuff you mentioned – I would put a note at the top of the comments wall that explains what the policy is (we take down spam and other words that are or appear to be illegal or inappropriate for this space).

after that – what is the big deal about disagreement? make it an opportunity to get feedback, we need it.

If you look at some blogs that are controversial (take penelope trunk’s blog for example, which I find to be the best in the business) she actually purposely puts content out there that will generate insane discussions and opinions.

I remember most vividly when she described an argument between herself and her husband where she ended up smashing a lamp over her OWN head! boy was everybody in there. I urged her to get serious mental help. But she is also a career columnist with some of the best advice I’ve ever seen. And she mixes the career stuff with her personal life. it keeps people reading and launched a brand (brazen careerist) that I participate in (social network).

You might say, we are government and serious and that stuff is “junk.” but I say, precisely BECAUSE we are government and serious we are putting people off and they’re not getting the information they need. we need to come down a level and get with the people. The people are on FB. And if we don’t give them a microphone they will go somewhere else or not read at all.

Honestly the way FB is going (very commercialized and generic) I am thinking that personal social networks are the wave of the future, in which case it will be harder and harder for gov to be heard unless we are nimble about how we jump in and out of conversations. to do that we need to stop worrying so much.

Bottom line – confidence + disclaimers + tie our activities to operational need and it should be OK.

Thanks for an interesting post.

Peter Sperry

I am a little unclear how comment and spam policies coexist with federal records laws. My understanding is that agencies are required to record, retain and make available for review all public comments recieved during hearings, public meetings, regulatory comment periods etc. Essentially, any communication which includes one or more individuals who ar nt federal employees is subject to sunshine laws. So how can a social media manager “take down” comments they find objectionable without violating the law? Do they copy them and make them available offline? Would they be available if a member of the public filed a FOIA request?

Eric Erickson

Dannielle – I’ve never heard of Peneolpe Trunk’s blog…will definitely check that out.

Jeffrey – In response to your two questions:

What would you do if someone posted 5 times/day to say that IRS is stealing taxpayers’ money?

We would remove the posts since they are not related to IRS Recruitment. Our page info clearly states that all posts not related to IRS Recruitment are removed.

What would you do if someone posted 25 times/day to say that they disagreed with how IRS did its hiring?

This has not happened, and honestly, I don’t want to speculate – there are probably 1 million different scenarios you could come up with about how people could or might post on a Facebook wall. When they occur, we approach it thoughtfully and within the guidelines we created for our wall. In a case like this one, it would depend on the actual question and the tone of the post. I can say that the vast majority of people who post on our page know the drill…they want answers to questions and are not there to rock the boat.

Stefeni C. Heyerdahl

Mr. Levy, I totally agree with you. There aren’t many ways to sensor incoming comments that aren’t appropriate for your subject matter, so I’m stuck in the middle there. But, if you’re going to have that sort of thing (@FB), you have to take the good with the bad. Its a real shame that some are just too childish to be adult about things – thats whats so frightening.

Jon Lee

I think it depends on your agency and how you tie your social media initiative to your business goal. For example, if you’re a Veterans’ Commission and your objective is to provide helpful resources and relevant links to veterans, I don’t see a problem with allowing people to post, because you’re representing your industry, not just your agency. Your fans will have very useful knowledge that you didn’t know about, and allowing them to share it makes your community that much stronger. Of course, you’ll have crystal clear policies for engagement and moderation, and you must have staff that can monitor the site throughout the day.

And if your another agency whose objective is to just broadcast information and respond when necessary, then no, you don’t need to enable fans to post.

Brett White

I am a little unclear how comment and spam policies coexist with federal records laws.

This is the crux. I think it’s going to take a lawsuit to define that one, unfortunately. What we may call reasonable, intelligent, moderation or comment/content policy isn’t necessarily what an angry (and well-funded) constituent may call it. To him/her, it’s censorship and/or a freedom of speech violation.

Is it a public forum? Is it a limited public forum? Does gov’t speech doctrine override things? I don’t want our municipality to be the guinea pig on figuring that one out. And this is why we have the engagement bar low for now.

Jeffrey Levy

@Eric – the problem is that we *have* faced those scenarios. We’ve had people try to overwhelm our page with their own posts. This isn’t theoretical.

Kurt Williams

@Peter “all public comments recieved during hearings, public meetings, regulatory comment periods etc.”

So how can a social media manager “take down” comments they find objectionable without violating the law? Do they copy them and make them available offline? Would they be available if a member of the public filed a FOIA request?

I think that Facebook does not count towards any of any of those you mention. How can government be responsible for comments made on a posting such as “Chili cook off at the recreation center on Sunday.” Facebook posts and comments as of now are not able to be backed up as far as I know. There may be a third party software that does it but FB does not.

Peter Sperry

@Kurt — why would Facebook not count as a public comment venue subject to federal records laws? FB may not provide the capability of recording or backing up comments but that would not change the legal requirement. I would think an agency would face some very tough questioning regarding compliance if they were unable to respond to a FOIA request based on a third party vendor’s inability to meet legal requirments. The first question minght be “Why are you soliciting comments on a platform that does not allow you to comply with black letter law?” Federal agencies are not responsible for the content of comments made regarding chili cook offs but my understanding is that they are responsible for accurately recording those comments and making the record available to other members of the public if requested.

Brett White

Specifically regarding FB…

With the recent enhancement of their Fan pages, you can get notified every time someone comments. Archive that email. There you go. 😉

Adriel Hampton

Peter, with the caveat of not being a lawyer or expert in federal records laws, I think you’re going way, way out to the extreme. Most conversations between government employees and citizens are not recorded. Think about phone calls and constituent meetings where notes are not taken. Facebook is difficult only because it is written material – and I know there are agencies that do keep copies of every post they delete for violating comment policies.

Peter Gillis

I’m on Eric’s side. It’s a socialization issue. We have our terms of participation posted, and they are enforced. We have not seen any misuse of the medium, and we allow posts because our constituents are all over the country. There might be issues in South Carolina that would generate some quality discussion.

I too was worried about the worst-case scenarios (off-topic posts, people monopolizing the page), but I decided to cross those bridges if I came to them. I haven’t. Let the people be heard.


Great discussion in the thread.

My two cents:

-I like Jeffrey’s approach as seem to strike a good middle. However, I do think that varies a lot across agencies – EPA is a large federal agency with a large population interested in it. For much smaller agencies and smaller local governments, it may be better to allow individuals to submit their posts and not just comment. Part of it is simply based on real-world feedback – if open and too many annoying posters, then go more controlled. We’ve even done this on GovLoop – where anyone can write a blog post but we feature the best ones on the home page. People have told me they like that curation a lot better than just having anyone post and show up

Peter Sperry

I like Brett’s solution re FB. It is simple, eloquent and meets legal requirements.

The problem we face is multifaceted. Disclosure, open government and ethics laws written in the mid to late 20th century run up against rapidly evolving 21st century communication platforms in a highly conflicted political environment where extremes become the new normal and partisans on all sides are playing high stakes gotcha. State and local governments operate under their own set of laws and regulations, but it is the feds who will attract the most attention. Keep in mind, it is the EPA FB page Jeff is describing. In the current political environment, FOIA requests and legal questions are a question of “when” not “if”. On the bright side, you can always use these challenges to squeeze more funding and personnel authorizations out of the budget shop.

Lorne W. Neff

If its relevant to what we do, we fully encourage posting whatever media. Ultimately, we want our Facebook Page to be everyone’s site. Everyone who friends us is more than a friend, but a member of our family and has a voice. Your booth is your website, use that as your megaphone…restrict that. Your Face Book page is your front porch, stop by, set a spell, bring the kin’, share…

I think there’s a tendency to way over analyze the whole web experience and try to justify everything and optimize everything. Somethings don’t have to be that complicated.

Kevin Lanahan

I think it helps if your FB page is focused. As a state agency, we’ve got a limited appeal (Missouri hunters, anglers, hikers, etc) and don’t get the random flak that a federal agency may get.

That being said, at, we allow users to post comments and questions, but not photos or videos. It’s basically an extension of our outreach program, and we’re reaching thousands of people that would never think to call or write to us, or to stop in our offices.

Our comment policy (based on several great examples, including the EPAs) says we’ll delete anything that is off topic, hateful or denigrating. So when someone comments that we need a new nuclear plant in MO, that’s not on topic and gets deleted. If they comment on what effect a new nuclear plant would have on wildlife or fish, yeah, that’s relevant to us.

Keep a log of deleted comments and, when possible, notify the user that her comment is being deleted and why. Sometimes someone makes a great comment, but uses a naughty word, and we’ll tell him that we are deleting the comment, but ask him to repost without the vulgarity.

Ed Cunningham

Definitely not good to let them take over and post anything on your wall — you should control those messages. But still, some will hijack your discussions anyway with their own agendas even in the comments section. We had to kill our very popular FB page completely because it became a major distraction from our message when some people incessantly made long, irrelevant comments attacking individual people — on every single post. We did not want to facilitate libel by allowing it, or limit free speech by removing the comments. We didn’t have a legal team to babysit the page 24/7 to determine what’s in or out, so now it’s gone altogether. Has anybody else found a solution to this kind of trouble? As you probably know, FB wont let you turn off all commenting on an organization’s page the way you can on an individual’s FB account.

Ed Milligan

I agree with Adrielle! If you’re going to have a public facing social media presence, manage content by posting a clear caveat about the purpose of your page and rules of engagement. People post comments because they want to be heard…whether its a complaint or a compliment–they want the visibility/credit as one who generates great discussion or as an individual who clearly appreciates the efforts of those behind their taxpayer dollars.

For those in the audience who chose to be a bit “on the edge” and almost flame their opinions, its an opportunity to learn the value of strategic communications. Controversial content gets people talking about it, reading it, and…commenting on your content. So, take a deep breath, ensure you have a person dedicated to watching your branding and PR temperature and engage when/where necessary.

WRT social media, it’s easy to just take your ball and go home, or decide not to even bother playing at all. But this and future generations are growing to expect the ability to engage when the thought/feeling/opportunity arises. Our laws for Freedom of Information will surely continue to progress to a point where the majority of data and decision making processes are required to achieve greater and greater levels of transparency. Learning how to interact respectfully with a more educated and engaged public is something that none of us will be able to avoid.

Chris IRS Recruiter

Hi Jeffery,

Great discussion, I work with Eric Erickson in the IRS Recruitment Office; he mentioned that you had some specific questions about how we manage our Facebook page. You might find our latest blog interesting.

Jeffrey Levy

Hi everyone. Thanks for a terrific discussion so far. I’ve been buried in working on our response site for the Japanese nuclear emergency, so haven’t had a chance to absorb everything yet.

Jeffrey Levy

Here’s an example that just happened: one guy posted 13 times in 12 minutes. None of it was “off-topic” in that it was all about the environment. But the posts were his agenda.

If we’d allowed him to post to our wall and be visible, he would’ve shoved everything we’ve posted off.

Brett White

Yep, Jefferey, therein lies the issue. Our City views Facebook as a public forum, so, we don’t delete comments we “don’t like” or could be considered an abuse of the forum. Just like we don’t censor…um…highly opinionated/borderline gadflies who may want to comment at Council meetings. Same venue, different medium.

This is why we’ll most likely never allow fans to roll their own content on our wall. The way it is now, we at least maintain some control over the conversation. We can always post a bunch of other stuff on top of trouble-inducing content to push it down to page 2 and out of immediate sight.

Jeffrey Levy

Brett: to be clear, we don’t delete comments unless they violate our comment policy. Criticizing us is fine as long as they don’t use foul language or violate a few other common things.

Ed Cunningham

Yes, we didn’t want to stop the public forum either, but our attorneys were concerned that there is not enough case law relating to social media to be certain as to which”comment policies” are legally acceptable and which are not. If FB is truly a free and open forum, then why wouldn’t a city allow profanity? Do police stop people from using profanity on the streets? What makes FB different? What authority says FB is the same as a Council meeting and not the street corner? We heard a high-level opinion from a state official who said to remove no comments, not matter how bad, even if it rises to a criminal level. Then it would be a police issue. It’s this lack of legal clarity that concerned us, so we pulled the plug before we became unwittingly responsible for some kind of injustice — one way or the other.

Jeffrey Levy

Ed: differing legal opinions is one of the things slowing down gov’t use of social media. Our attorneys believe FB and our blog are just like a public meeting, where rules of decorum do apply. Does it help to show your attorneys the hundreds of other agencies who apply very similar comment policies?

Rex Morriss

An important issue that MUST be addressed is the problem of elected representatives (Congress and Senate) who maintain FB pages, but flatly REFUSE to allow public comment – or allow it ONLY from those who post favourable, supportive comments agreeing with their stance on the issues while actively blocking (and removing the posts) of those who disagree with their stated positions – even in a totally polite and civil manner. (I can understand blocking abusive users, but not blocking on the basis of policy disagreements.) Such is the case with our Congressman, Doug Lamborn, who routine blocks and removes users and comments he finds to be a challenge to his established policy viewpoints, while still attempting to convince his constituents that he’s interested in what we all have to say about the issues of the day. Such could not be further from the truth. I would like see a rule change in which ELECTED GOVERNMENT REPRESENTATIVES are REQUIRED to allow open, unfettered access and unimpaired opportunity for their constituents to access their public Facebook pages and prohibiting said Representatives from blocking those who may not agree with their policy statements. If we believe in Representative government at all, assuring full, open public participation within the context of social media needs to be a mandate, not an option.