Decision making guidance: concerns relating to social workers communicating online

Last updated: 20 August 2025

• About this guidance
• Additional matters to consider when reviewing online communication
• Related policies, procedures and information sources

About this guidance

Why do we need this guidance?

When we receive concerns about social workers and their online communication, we need to consider them on a case-by-case basis to determine whether they raise any fitness to practise concerns.

Who needs to follow this guidance and why?

This guidance has been developed to assist decision makers in considering these concerns. Decision makers include (all of the following): 

• triage staff 
• case examiners 
• adjudicators 

What’s our guidance and how will we implement it?

We need to be mindful that social workers have the following rights as set out in the Human Rights Act 1998:

• Article 8: Respect for your private and family life, home and correspondence
• Article 9: Freedom of thought, belief and religion
• Article 10: Freedom of expression
• Article 17: Prohibition of abuse of rights

As social workers need to uphold the professional standards, there needs to be a balance between these rights and their responsibilities. You should also consider (all of the following): 

• Professional standards
• Professional standards guidance
• Communicating online: guidance for social workers

The most relevant professional standard is: 

‘As a social worker, I will not: 

5.6 Use technology, social media or other forms of electronic communication unlawfully, unethically, or in a way that brings the profession into disrepute.’ 

However, there may be other professional standards that are also relevant including (but not limited to): 

• 1.2 [As a social worker, I will] Respect and promote the human rights, views, wishes and feelings of the people I work with, balancing rights and risks and enabling access to advice, advocacy, support and services. 
• 1.5 [As a social worker, I will] Recognise differences across diverse communities and challenge the impact of disadvantage and discrimination on people and their families and communities. 
• 1.6 [As a social worker, I will] Promote social justice, helping to confront and resolve issues of inequality and inclusion. 
• 2.2 [As a social worker, I will] Respect and maintain people’s dignity and privacy. 
• 2.6 [As a social worker, I will] Treat information about people with sensitivity and handle confidential information in line with the law. 
• 3.1 [As a social worker, I will] Work within legal and ethical frameworks, using my professional authority and judgement appropriately. 
• 3.7 [As a social worker, I will] Recognise where there may be bias in decision making and address issues that arise from ethical dilemmas, conflicting information, or differing professional decisions. 
• 5.1 [As a social worker, I will not] Abuse, neglect, discriminate, exploit or harm anyone, or condone this by others. 
• 5.2 [As a social worker, I will not] Behave in a way that would bring into question my suitability to work as a social worker while at work, or outside of work. 
• 6.1 [As a social worker, I will] Report allegations of harm and challenge and report exploitation and any dangerous, abusive or discriminatory behaviour or practice. 

Discrimination has a specific legal definition under the Equality Act 2010 [1] and this language should not be used lightly when describing a social worker’s conduct. It is important not to encourage a culture of hypersensitivity or the imposition of legal responsibility in respect of every unfortunate phrase. You should seek legal advice if you consider that the social worker’s conduct may have amounted to ‘discrimination’.

[note 1] Discrimination includes:  

• direct discrimination (section 13) 
• indirect discrimination (section 19) 
• harassment (section 26) 
• victimisation (section 27)

Additional matters to consider when reviewing online communication

1. From an objective perspective, are the comments inappropriate or do they contain offensive material and if so, why can they objectively be considered ‘offensive or inappropriate’?

It is an objective assessment whether content will offend or undermine public confidence. You should review the online content carefully. You should consider the tone used and also read the content in context. For example, if comments relate to news articles or content of another person or organisation, then you should review that material in detail as well. You should consider whether the comments were being made in the context of a legitimate political or social debate. 

You should also consider whether the ‘belief’ expressed by the social worker could be a ‘protected characteristic’. If the protected characteristic is a belief, do the comments have a direct and close connection to the protected belief so you can understand them clearly as manifestations of that belief? 

You should remember that the social worker is entitled to express their beliefs. But they should not do it in a way to which objection could justifiably be taken (for example, in a way that causes an inappropriate level of offence). 

You should consider whether there is evidence of further offence being caused beyond the person who initially raised the concern. For example, have we received any further complaints about the content? You should not just accept a complaint from one side of a legitimate divisive debate at face value. 

There should be an appropriate objective balance of the potential validity of different views. It is important to remember that the assessment of whether the content is potentially inappropriate or offensive might depend on knowledge of cultural or historical context.

If you have identified a social worker’s content as being potentially inappropriate or offensive, you need to explain specifically why this is. If you have identified various content as being inappropriate or offensive, you should distinguish appropriately and consistently between them. 

For example, is it because (any of the following): 

• the social worker has shared confidential details of a service user?  
• they are engaging in harassment, bullying, or threatening behaviour? 
• they are using offensive language such as slurs, profane language, inciting violence, racially abusive language [2]? 
• there are aggravating factors such as ‘discriminatory’ comments, for example were the comments directed towards a person or group with a protected characteristic as defined under the Equality Act 2010 [3]? 

As a public authority, we have wider legal obligations which ensure equality is at the heart of what we do. The public sector equality duty was created by the Equality Act 2010 and requires us to (do all of the following): 

• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act 2010 
• advance equality of opportunity between people who share a protected characteristic and those who do not 
• foster good relations between people who share a protected characteristic and those who do not 

Conduct directed towards a person or group with a protected characteristic, because of or related to the protected characteristic, would likely be considered more offensive and inappropriate. This would be more serious than if it was aimed at the general public.  

Protected characteristics [4] include: 

• age 
• disability 
• gender reassignment 
• marriage and civil partnership 
• pregnancy and maternity 
• race 
• religion or belief 
• sex 
• sexual orientation 

There are constant legal developments in this area.  You should seek legal advice if you are not clear as to whether something is a ‘protected characteristic’.  

If you consider the comments could be inappropriate or offensive, you should then consider whether the conduct can call into question the social worker’s fitness to practise by reference to the wider public interest, by considering the next factors 2-6. 

[note 2] PSA v HCPC & Roberts [2020] EWHC 1906 (Admin) at paragraph 61, 62 and 63 where it was discussed that conduct of a racist nature was likely to result in a finding of impaired fitness to practise

[note 3] Section 4 of the Equality Act 2010 sets out definition of protected characteristics 

[note 4] Section 5 -12 of the Equality Act 2010 sets out further detail of each ‘protected characteristic'

2. To what extent can it be said that the online content was supported by or endorsed by the social worker themselves?

For example, has the social worker (done either of the following): 

• posted the content or made the comments themselves? 
• ‘retweeted’ or ‘reposted’ some content that may be problematic? 

If the social worker has not posted the content or made the comments themselves, for example have they (either of the following): 

• acknowledged someone else’s post that may be problematic? 
• been mentioned or tagged in a post that may be problematic? 

How much can the social worker be said to ‘support’ or ‘endorse’ the potentially problematic content? Is there another way to view the social worker’s online engagement that may not be ‘supporting’ the problematic content? Does the fuller context indicate that the social worker refutes, denounces or condemns the problematic content?  

3. To what extent were the views expressed in the social worker’s private or professional capacity?

This is relevant in considering the public interest and the extent to which the social worker’s conduct may undermine confidence in the profession.  

For example, if the content was inappropriate and the social worker has (any of the following):  

• clearly supported or endorsed that content, and the social worker was identifiable as a social worker on the online platform 
•  used their status and/or experience as a social worker and/or registered professional to support, give credibility to or create trust in their comments  
• referred to their professional life and/or the social work profession, this is more likely to undermine confidence in the profession. 

If the social worker expressed views solely in a personal capacity and was not identifiable as a social worker, this may impact on whether the conduct would undermine confidence in the profession. You should move onto factor 4. 

4. If content was shared in the context of the social worker’s private life, to what extent does the conduct engage the professional standard, 5.2?

For example, could the content impact negatively on (either or both of the following): 

• the social worker’s ability to engage with a range of service users with different backgrounds? 
• the confidence service users may have in engaging with them as a social worker?

5. To what extent were the comments in the public domain and/or are publicly accessible?

For example, you should consider (both of the following): 

• whether there were any privacy settings in place and if so how restrictive were these 
• if the content was shared in a private space, how private was that setting? Was it a small group of colleagues sharing content in a closed group space? Was it an open and public group that anyone could join?  

The more public the sharing of the content is, the more likely it may be to undermine confidence in the profession. 

6. To what extent has the content shared online reflected on the ability of the social worker to practise as a professional?

You should consider whether there is any evidence to suggest that the social worker’s fitness to practise has been noticeably impacted by the content shared. 

For example: 

• if the social worker has expressed objectively inappropriate or offensive opinions or comments, is this reflected in their practice or could it impact their practice? 
• how close is the link between the social worker’s comments and their practice, especially if there are no aggravating factors? 
• is there any direct harm or a risk of harm to service users, colleagues or to the social worker’s professional life? 

If there isn’t a close link to the social worker’s practice, or it relates to their private life, it is less likely that this would raise concerns about a social worker’s fitness to practise. This is because there is a high threshold for a regulator to interfere in a social worker’s private life.[5] Any interference must be justified to explain how it impacts on public confidence in the profession and professional standards, and how the public interest outweighs the social worker’s right to a private life. If there is no public protection risk, there is a high bar to find that someone’s fitness to practise is impaired on public interest grounds alone. This includes maintaining public confidence in the profession.  

However, if the comments and views suggest a deep-seated attitudinal or character concern, or if the conduct might amount to unlawful behaviour, it is more likely to impact on a social worker’s fitness to practise. It is also more likely that there is a risk to service users.

When considering whether the high bar has been reached to properly seek to interfere with the social worker’s right to freedom of expression, we should analyse whether the content is offensive or inappropriate. If yes, we should consider whether that amounts to a breach of the professional standards. 

Where the content is an expression of a political belief that could reduce the public’s trust in the social worker or in the profession, the relevant content will need to do more than cause offence. Even where the speech is seriously offensive, you must closely consider the facts to establish whether the speech has gone beyond the latitude allowed for the expression of a political belief. [6]

For example, does it involve personal abuse, derogatory racist or sexual language?  

This is more likely where the social worker has (done either of the following) 

• engaged in harassing, discriminatory [7], threatening or victimising behaviours  
• demonstrated views which are discriminatory or racially abusive or motivated 

These views are more likely to be incompatible with professional practice and being a registered professional, even if there is no direct evidence of harm or impact on their practice. These views and behaviours can have a particularly negative impact on public trust and confidence.  Members of the public may avoid using social and care services as a result. 

It is more likely that these will raise fitness to practise concerns if there is more evidence that the social worker’s views online have a direct and negative impact on their professional practice.  

[note 5] Husain v SRA [2025] EWHC 1170 (Admin) at paragraph 35

[note 6] Holbrook v BSB (Case 2021/4441, 25 March 2022) at paragraph 44

[note 7] directed towards a person or group with a protected characteristic as defined under the Equality Act 2010

Is this an isolated incident or a pattern of behaviour?

We may not need to take regulatory action for isolated incidents. This is unless the comments suggest that there may be an attitudinal issue, such as displaying discriminatory or racially abusive views. Even if there is only one reported incident, it may indicate a deep-seated attitudinal and character flaw or issue. A pattern of incidents is more likely to demonstrate a risk to service users and more likely to raise fitness to practise concerns. 

Is there any evidence affecting the social worker’s culpability for the behaviour?

We should also consider whether there is any evidence which would negate the social worker’s culpability. This includes having a medical condition that may impair their ability to understand the nature of what was being communicated or being able to take a rational decision about whether to communicate the content or not. 

Related policies, procedures and information sources

• Communicating online – guidance for social workers