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Maryland Passes First Social Media Law Preventing Employers from Demanding Applicant Passwords

Maryland comes up first in the legislative race throughout the states in passing what many may consider essential legislation protecting employee and applicant privacy rights as it pertains to social media account information. Illinois and California have measures that have recently passed through legislative committees, while bills are still being considered in New York and on the federal level. (See my blog on March 21, 2012: http://socialaxcess.com/2012/03/21/can-companies-really-ask-for-candidates%E2%80%99-facebook-twitter-passwords/)

Last week, Governor Martin O’Malley of Maryland signed the country’s first law restricting employers’ ability to demand social media account information from applicants and employees. The Maryland law takes effect on October 12, 2012, and contains the key points:

  • There is no “small employer” exemption, and covers all employers, as well as “an agent, a representative, and a designee of the employer.” Therefore, employers cannot avoid liability by contracting out to have someone else do what the law prohibits.
  • An employer is prohibited from requesting or requiring an applicant or employee to “disclose any user name, password, or other means for accessing a personal account or service through” a computer, telephone, PDA, or similar device. An employer may, however, require the disclosure of a user name and password to access non-personal accounts that “provide access to the employer’s internal computer or information systems.” (The difference being personal accounts versus work accounts.)
  • An employer cannot terminate, discipline or penalize an employee (or refuse to hire in the case of an applicant) based on a refusal to disclose any prohibited information (which the employer is now no longer able to ask for in the first instance).

Bottom line for employers in all states is to be cautious about how your recruiters and hiring managers go about obtaining social media-based information to reach decisions about applicants and employees. Stay tuned for more developments in this area.

Want to learn more about legal guidelines for recruiters? Join us this month in Chicago at the Social Recruiting Strategies Conference May 22-24th. http://socialrecruitingstrategies.com/chicago-2012/agenda.html

 

Kara Mignanelli
Ms. Mignanelli serves as Senior Vice President of People and General Counsel. In her role, Ms. Mignanelli oversees numerous aspects of the business, including, but not limited to, HR compliance and keeping a pulse on the most current regulations and compliance requirements affecting corporations as well as working to ensure quality and professionalism in all aspects of the business. Ms. Mignanelli has cross-functional experience in multiple areas including litigation, compliance, social media, privacy, employment law, intellectual property, estate planning, corporate formation, and risk management. She is responsible for all aspects of the company's legal needs and all HR. Ms. Mignanelli also created the Governance, Risk Management and Compliance summit in 2009 and more recently the HR Compliance and Social Recruiting Strategies Conferences. Prior to joining GSMI, Ms. Mignanelli was the managing associate at Boyd Contreras LLP. Her practice focused primarily on civil litigation involving business disputes. Ms. Mignanelli's litigation experience includes business litigation, partnership and contract disputes, personal injury, labor and employment law, trade secrets misappropriation, and legal malpractice. She also maintains a solo practice offering transactional legal services including estate planning, probate, family law and corporate formation. Before practicing law, Ms. Mignanelli was Director of the Social Policy Center at the Performance Institute where she managed conference production staff and successfully executed over 30 conference and training events, accounting for the largest profit generating center of the company.

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