EMultiservices Ltd Content Policy, hereinafter EMS (Internal)
Document owner: Alexandri Gutierrez Hortua / CEO
Version: 1.0
Effective date: 01 January 2026
Applies to: All EMS staff/contractors who publish, respond or send messages on behalf of EMS via the website, WhatsApp, Facebook, Instagram, TikTok, YouTube, email and SMS.
1. Purpose
This policy ensures that EMS content is accurate, responsible and compliant, and that EMS does not provide regulated legal advice nor create confusion regarding its regulatory status.
2. Our positioning
• EMS provides general information, content creation, marketing/community management and administrative support (e.g., document checklists, appointment coordination).
• EMS is not a law firm and is not authorised or regulated by the Solicitors Regulation Authority (SRA).
• EMS does not carry out reserved legal activities and does not provide individual legal advice.
• Where legal advice is required, EMS may refer/direct individuals to an independent regulated professional.
3. Content we may publish
Permitted content:
• General updates on procedures/regulatory changes in the United Kingdom with links to official sources (e.g., GOV.UK, regulators).
• High-level general explanations (“how the process works”).
• Neutral checklists: typical documents, typical steps, typical timelines (avoid guaranteeing outcomes).
• Educational content on “common mistakes”.
• Videos on how to prepare for a consultation with a regulated professional.
• Cases/experiences only if fully anonymised and with permission where applicable.
4. Content we must not publish
Prohibited content:
• Any statement implying EMS is a law firm or provides legal services (e.g., “our lawyers/solicitors”, “legal representation”, “we represent you in court”).
• Individualised legal guidance:
• “You qualify”, “Apply for X visa”, “Your best option is…”, “Do Y to win your case”.
• Requesting or publishing personal documents in public comments/groups (passport, BRP, addresses, case numbers, bank details).
• Guarantees or promises of success (“100% approved”, “guaranteed outcome”).
• Misleading advertising, unclear pricing or material omissions.
• Defamatory or discriminatory content.
5. Accuracy and sources standards
• Verify before publishing: check data against primary sources (GOV.UK, regulatory guidance, legislation).
• Include dates (“As at 2026”) where rules change.
• Maintain internal notes of sources used for each educational post.
• If in doubt, do not publish—escalate to Head of Content.
6. Mandatory disclaimers
All posts/videos/copy on legal/immigration topics must include (or link to) a disclaimer similar to:
“General information only — does not constitute legal advice. EMultiservices Ltd is not a law firm and is not authorised or regulated by the SRA. For legal advice, consult a qualified regulated professional.”
7. Handling comments/DMs and escalation
7.1 Public comments
• Do not respond to case-specific queries in public.
• Use approved template:
“Thank you for your message. For privacy reasons and because each case is different, we cannot provide individual guidance here. Please message us privately if you would like general information and next steps. If you require legal advice, we can refer you to an independent regulated professional.”
7.2 Direct messages (DMs)
• Before requesting documents, share the Privacy Policy link and obtain confirmation of acceptance.
• If legal advice is requested:
“We cannot provide legal advice. We can assist with administrative support and, if you wish, refer you to an independent regulated professional.”
7.3 Escalation triggers (mandatory)
Escalate to the General Director if:
• There are allegations of misconduct, fraud, threats, self-harm or vulnerability.
• A user shares sensitive documents publicly.
• A regulator or government body contacts you.
• Content could be interpreted as legal advice or representation.
8. Group rules (WhatsApp/Facebook)
Pinned message must include:
• Do not share personal data in the group.
• No case-specific advice.
• Moderation rights (remove content/expel members).
• How to contact EMS privately.
9. Records
Retain records of:
• promotional claims and supporting evidence,
• messages linked to complaints,
• marketing consents/opt-ins,
• moderation/removal actions (where possible).
10. Training and enforcement
All staff/contractors must receive initial training and refresher training every [6/12] months. Breaches may result in removal of publishing permissions and disciplinary measures.