Creating an Ironclad Social Media Policy
There are a lot of opinions for and against the need for social media policies in the workplace. And many good points on both sides. But the bottom line is this: any business owner or senior manager interested in protecting the company brand and reputation must ensure that it has in place some form of social media policy.
Creating an Ironclad Social Media Policy July 2010 Jesse Torres Jesse Torres is President and Chief Executive Officer of Pan American Bank in East Los Angeles, California. He is a regular speaker at banking industry conferences and seminars. Prior to joining Pan American Bank he served as President and Chief Operating Officer of Security Savings Bank in Henderson, Nevada. Mr. Torres is a former regulator with the Office of the Comptroller of the Currency (OCC) and served as a Senior Consultant for KPMG Peat Marwick as well as has held senior officer positions at several banks in the Los Angeles area. Jesse is the author of the Community Banker’s Guide to Social Network Marketing (December 2008) (http://bit.ly/bankersm) and Community Banker’s Guide to Hispanic Marketing (January 2005) (http://bit.ly/hispanicmarketing). Mr. Torres is a graduate of UCLA and the Pacific Coast Banking School at the University of Washington. Jesse can be reached by e-mail at MrJesseTorres@gmail.com. He can also be found on LinkedIn at www.linkedin.com/in/jessetorres. Download a copy of this ebook at http://bit.ly/ironcladpolicies. To receive updates to this whitepaper and notices of new related whitepapers, send an email to UpdateSocialMediaPolicy@gmail.com. Comments, corrections and other feedback may be sent to the author at MrJesseTorres@gmail.com. This whitepaper is for informational purposes only and should not be considered legal advice. © 2010 Jesse Torres Unauthorized duplication of this material is a violation of copyright. V20100701 Creating an Ironclad Social Media Policy Jesse Torres TABLE OF CONTENTS INTRODUCTION ............................................................................................................. 1 FORMS OF SOCIAL MEDIA ENGAGEMENT ................................................................ 3 SOCIAL MEDIA POLICY COMPONENTS ...................................................................... 6 Provide the Policy to Everyone 6 Make the Policy a Living Breathing Document 7 Monitor Others Social Media Failures and Successes 8 Make the Policy Broad in Application 8 Disclaim When Possible 9 Remind Employees that they are Brand Ambassadors 10 Be Honest and Transparent but Confidential 11 Give Employees Leeway to Respond in Their Own Voice 12 If Necessary, Invoke a Social Media Review Process 12 Experiment and Have Fun 13 WHO SHOULD FRAME THE POLICY? ........................................................................ 14 Marketing and Public Relations Departments 14 Legal and Compliance Departments 14 Customer Service Department 14 Employees 14 DISTINGUISHING BETWEEN COMPANY AND PERSONAL ...................................... 15 USE OF SOCIAL MEDIA TEMPLATES ........................................................................ 16 CONCLUSION .............................................................................................................. 17 REFERENCE MATERIAL ............................................................................................. 18 Creating an Ironclad Social Media Policy Jesse Torres INTRODUCTION To paraphrase Bono, there’s been a lot of talk about social media policies, maybe too much talk. There are a lot of opinions for and against social media policies in the workplace. And many good points on both sides. But the bottom line is this: any company interested in protecting the company brand and reputation must ensure that it has in place some form of social media policy. Source: marketingtulen.files.wordpress.com Critics of social media policies say “you can’t control what is uncontrollable!” “You can’t be everywhere to review everything employees have to say!” Agreed. And that’s exactly why a social media policy is necessary. A social media policy is not intended to “control” employees. Its purpose is to give employees guidance and keep them from making a Career Altering Decision. No policy can control an employee. The best a policy can do is guide employee actions. In a perfect world companies hire individuals that are smart, capable and masters of common sense. Unfortunately we don’t live in that world. In our world, smart, capable and generally common sensical employees make dumb decisions from time-to-time. Further, for many companies, the youngest employees, while smart and capable, many times lack the experience and maturity needed to make all the right decisions all the time. And it is these employees that are likely the most experienced and heaviest users of social media. Businesses are not only in the business of making or servicing widgets. They are also in the business of making and servicing the company’s brand. Through a coordinated 1 Creating an Ironclad Social Media Policy Jesse Torres social media effort, companies can enhance their brand and competitive advantage, resulting in greater revenues. However, lack of attention to social media activities can have the opposite effect. As a result it is in every company’s best interest to establish guidelines for social media usage. Source: www. blogging4jobs.com Businesses are in the brand-building business. The stronger the brand, the greater the revenues. Companies need to make sure that their social media policy covers not only official company business but also the personal social media interactions of employees that directly affect the company’s brand. There is a growing list of employee-related social media blunders, each having the potential to adversely affect the company, its brand, reputation and revenues. While a social media policy, like any policy, will not eliminate all the risk, it reduces the risk and hopefully lessens the effect of a social media crisis. 2 Creating an Ironclad Social Media Policy Jesse Torres FORMS OF SOCIAL MEDIA ENGAGEMENT Social media engagement can take many forms. Engagement can take place on blogs, YouTube, Facebook, Twitter, product review sites, virtual worlds, news sites, etc. A company’s engagement may result from both “official” company activities such as company blogs as well as from the personal interaction of employees on their social media platforms of choice. Social media policies are essential to guide employee interactions while conducting company business such as posting a YouTube video featuring the company president, posting Flickr photos from a company-sponsored event, posting a company event on MeetUp, posting a comment on Facebook, responding to a tweet on Twitter, commenting on a news article in the local paper’s Web site, or some other official company response. Source: cdn.mashable.com The company’s employees may also use social media platforms on their personal time. At times, employees may involve the company on an “unofficial” basis, either through a direct reference to the company (e.g., a post that informs readers that the commenter is an employee of the company) or indirectly (e.g., company name on a LinkedIn profile). Unofficial engagement can take place in many ways. For example, a company employee may respond to a tweet that disparages the company. The employee may hastily and rudely respond, thinking the response is a legitimate defense of the company. Instead, the response may be attributed to the company as a rude and disrespectful “official” response, damaging the reputation of the organization and creating damage to the brand. 3 Creating an Ironclad Social Media Policy Jesse Torres Source: www.smithcoconsultancy.com The following Dvorak Uncensored blog post describes an actual social media-based fiasco involving Domino’s Pizza: When two Domino’s Pizza employees filmed a prank in the restaurant’s kitchen, they decided to post it online. In a few days, thanks to the power of social media, they ended up with felony charges, more than a million disgusted viewers, and a major company facing a public relations crisis. In videos posted on YouTube and elsewhere this week, a Domino’s employee in Conover, N.C., prepared sandwiches for delivery while putting cheese up his nose, nasal mucus on the sandwiches, and violating other health-code standards while a fellow employee provided narration. The two were charged with delivering prohibited foods. By Wednesday afternoon, the video had been viewed more than a million times on YouTube. References to it were in five of the 12 results on the first page of Google search for “Dominos,” and discussions about Domino’s had spread throughout Twitter. As Domino’s is realizing, social media has the reach and speed to turn tiny incidents into marketing crises. ”We got blindsided by two idiots with a video camera and an awful idea” said a Domino’s spokesman, Tim McIntyre, who added that the company was preparing a civil lawsuit. “Even people who’ve been with us as loyal customers for 10, 15, 20 years, people are second-guessing their relationship with Domino’s, and that’s not fair.” In just a few days, Domino’s reputation was damaged. The perception of its quality among consumers went from positive to negative since Monday, according to the research firm YouGov, which holds online surveys of about 1,000 consumers every day regarding hundreds of brands. “It’s graphic enough in the video, and it’s created enough of a stir, that it gives people a little bit of pause,” said Ted Marzilli, global managing director for YouGov’s BrandIndex. 4 Creating an Ironclad Social Media Policy Jesse Torres The Domino’s experience “is a nightmare,” said Paul Gallagher, managing director and a head of the United States crisis practice at the public relations firm Burson-Marsteller. “It’s the toughest situation for a company to face in terms of a digital crisis.” On Monday, commenters at the site Consumerist.com used clues in the video to find the franchise location in Conover, and told Mr. McIntyre about the videos. On Tuesday, the Domino’s franchise owner fired the employees, identified by Domino’s as Kristy Hammonds, 31 and Michael Setzer, 32. The franchisee brought in the local health department, which advised him to discard all open containers of food, which cost hundreds of dollars, Mr. McIntyre said. SOURCE: http://www.dvorak.org/blog/2009/04/16/ While a social media policy may not have prevented the incident noted above, it certainly would have advised employees of the legal risks they would face. That would likely discourage most from attempting such an act. As such, an adequate social media policy cannot eliminate all risk but it can go a long way in mitigating much of the risks. This whitepaper provides factors that should be taken into consideration when drafting a social media policy. These factors are not all inclusive but cover the key areas. Every company is different. As such, there is no one-size-fits-all policy. Regardless, there are certain factors that should be taken into consideration with every policy. This whitepaper will provide the guidance to creating a solid social media policy that seeks to provide flexibility while protecting the company brand and reputation. 5 Creating an Ironclad Social Media Policy Jesse Torres SOCIAL MEDIA POLICY COMPONENTS Provide the Policy to Everyone Whether or not a company has a formal social media strategy in place, every employee has the potential of participating in social media conversations on their own time that can have an effect on the company’s reputation. This is why it is important to not only have a policy in place but also distribute the policy to each company employee. Source: sivers.org To ensure broad initial distribution, apart from providing a copy to all existing employees, the policy should also be included with the company’s new employee orientation package. Further, because of potential changes in the social media environment the policy should be updated and distributed to all employees on an annual basis. Each employee should be required to acknowledge receipt of the policy each time it is provided. The company may also decide to make the policy available on the company intranet or on the Internet. In an effort to ensure that employees take the policy seriously and put forward due care, the company should include a statement in the policy regarding the potential for termination of employees for non-compliance. While the threat of termination may appear severe, the company’s brand and reputation can become severely damaged by careless or intentional acts. The intent of the policy is not to control employees but to guide their actions in a manner consistent with the expectations of social media as well as company and industry norms. If the policy is well crafted, employees should not feel confined or controlled and will be able to use their voice in their social media conversations without creating harm to the organization. 6 Creating an Ironclad Social Media Policy Jesse Torres Source: joyoftech.com Make the Policy a Living Breathing Document Social media is constantly evolving. Several years ago MySpace was the 800-pound gorilla. Today it is Facebook and Twitter. Tomorrow it is likely to be some other platform. Due to the rapid changes in social media, it is important that the company treat the social media policy as a living breathing document. This ensures that the policy remains relevant and does what it is intended to do – provide guidance. It is also important that the policy be as clear as possible to prevent misinterpretation and misunderstanding. Source: herd.typepad.com Many companies, due to the confidential nature of the information they maintain, implement information security and acceptable use policies that are reviewed and approved on an annual basis. It may make sense for a company that has such policies to piggyback the social media policy onto those policies to ensure that it is reviewed, updated and distributed at least annually. 7 Creating an Ironclad Social Media Policy Jesse Torres Regardless of the process used, it is important to ensure that employees understand that the policy is subject to change as the company and technology evolve. In an effort to keep the policy from being updated too frequently, a company can choose to maintain a separate “Questions and Answers” document that addresses specific questions that are too detailed to include in a policy but that may come up frequently. Monitor Others Social Media Failures and Successes It is beneficial for the company to monitor the social media successes and failures of other companies to determine whether an enhancement to the social media policy is necessary based upon the outcomes at other companies. This requires assigning the maintenance of the policy to a specific individual or department that will act as the custodian of the policy and will be responsible for ensuring its timely update and distribution. Source: www.hirelabs.com A simple Google Alert or similar method can inform the policy custodian of relevant information. For example, an alert using the search terms “social media” “failure” and “social media” “success” will inform the custodian when an Internet article occurs that mentions social media successes and failures. Other similar alerts can also be useful, such as “social media” and a description of the industry (e.g., “real estate” or “auto dealership,” etc.). These alerts will provide the ongoing monitoring that will make it possible to identify any necessary updates to the social media policy. Make the Policy Broad in Application In a few short years social media has gone from a handful of social networks to hundreds of social networks, each with its own niche and varying communication methods. Creating a policy that specifically names each platform will result either in rapid obsolescence or an incomplete policy. It is a better idea to broadly define social media as a technology that permits digital communication among users of blogs, social 8 Creating an Ironclad Social Media Policy Jesse Torres networks, wikis, video sharing sites, product review sites, virtual worlds, news sites and any other platform that provides for exchange of any type of information among its users. Source: www.localna8ion.com A policy that addresses every social media platform will not only be incomplete, it will be unnecessarily large and burdensome. Such a policy will be not be read and followed by employees, resulting in an ineffective policy and no meaningful risk mitigation. Disclaim When Possible One of social media’s greatest benefits is the ability to unleash a company’s employees as advocates of the company. This allows companies to leverage their ability to communicate and create dialogue on social media platforms. Each employee acting as a company ambassador can take advantage of opportunities that increase a company’s visibility and enhance brand awareness. Source: sgim.files.wordpress.com While the leveraging of employees provides significant benefit, it is also important that the social media community know that such comments are based on each employees personal opinions - opinions that may not be perfectly aligned with the company’s mission or vision. The use of a simple disclaimer by each employee informs the social 9 Creating an Ironclad Social Media Policy Jesse Torres media community that the comment is a personal comment and not an “official” company statement. This will act to protect the company from any comments that may be inconsistent, contrary or otherwise inappropriate. Remind Employees that they are Brand Ambassadors Companies can benefit by empowering and unleashing employees on social media. Most employees will act responsibly and understand that comments made can be negatively attributed to the company - even comments made as individuals on their own time. Regardless, it is important to remind employees that they are ambassadors of the company and that their actions have a direct effect on the company. It is important to stress that the policy applies even when they are off the clock to the extent that they associate themselves with the company. Source: www.andrinemendez.com The social media policy should encourage employees to seek opportunities that enhance the company’s brand and reputation while being aware of and avoiding situations that may cause damage the brand and reputation. This means employees must act in a manner consistent with the company’s norms (e.g., respectful tone, free of profanity, etc.). From time-to-time an employee may make social media comments from their personal accounts. At times such comments may be inconsistent with the company’s mission 10 Creating an Ironclad Social Media Policy Jesse Torres and vision or may be intentionally or inadvertently harmful to the company’s brand and reputation. In such cases, the policy should enable the company to demand the removal of comments as a condition of employment. While most companies seek for its employees a separation of personal and work life, the use of social media blurs these lines. As such, the social media policy should provide for the company’s right to demand that the employee delete commentary that is not only deemed inconsistent, but is also damaging to the company. In addition to protecting the company’s brand and reputation, the policy should demand that employees act and respond in an honest manner. Anything less is inappropriate and may result in significant damage to the brand and reputation. Social media is built upon the concepts of honesty and transparency. The social media community is not very forgiving when it comes to companies and employees that share information that is intentionally misleading or altogether fraudulent. While inadvertently incorrect information can be forgiven, it is best to have employees comment honestly or not at all. And while companies should encourage honesty and transparency, such comments should always be weighed against the potential for a serious and severe adverse outcome. There may be times when comments that create a serious and severe adverse outcome will be necessary (e.g., oil spill, breach of data, death caused by product, etc.). These comments, however, should be reserved for senior management. Be Honest and Transparent but Confidential Social media is about sharing and communicating in a transparent and honest manner. However, the need for transparency and honesty does not mean that employees are permitted to disclose confidential and/or proprietary information that can have an adverse effect on the company. Source: 3.bp.blogspot.com The policy should require that employees reveal their affiliation with the company to prevent criticism. This includes company and personal communications that reference or otherwise affect the company. The Information Technology Department should be consulted to establish a format for disclosing affiliation that provides appropriate disclosure and also protects the organization from social engineering attacks or similar tactics (e.g., Tom G., Sally, Marketing Department, etc.). Further, the policy should include reference to an external 11 Creating an Ironclad Social Media Policy Jesse Torres social engineering policy to ensure that employees are well versed in such risks that may arise from participation on social media platforms. The policy should explicitly prohibit employees from commenting on past, current or potential litigation. Any questions that might arise regarding litigation should be brought to the attention of the company’s legal department. Give Employees Leeway to Respond in Their Own Voice As long as employees are complying with the policy they should be given the latitude to respond in their own voice. Social media is about transparent and honest communication. This includes being heard in your own voice. While the policy may include an expectation of professionalism and standard of communication, there remains much room for individuality. The policy should encourage such individuality. Source: www.davemcrae.ca The company will benefit if it can unleash its cadre of social media savvy employees. However, employees will not act on behalf of the company if they cannot do so in their own words. Therefore, an effective social media strategy includes providing employees with sufficient flexibility to be heard in their own voice. If Necessary, Invoke a Social Media Review Process In most cases, a clearly written and well structured policy is enough to ensure protection against social media-related risks. However, certain organizations may remain uncomfortable regardless of the policy. In such cases, companies may implement a social media review process that would require prior approval before company- originated messages can be released on social media platforms. 12 Creating an Ironclad Social Media Policy Jesse Torres Source: penreflections.files.wordpress.com Implementation of a formal review process is not optimal in that it has a tendency of delaying and “whitewashing” the messages, both concepts that are inconsistent with social media. Regardless, in some organizations this may be the only route to implementing a social media strategy. “Champions” of social media within the company should do what is needed to have the social media strategy approved while giving senior management comfort. Champions should seek to decrease over time the extent of controls that adversely affect employee participation. Experiment and Have Fun There is no one-size-fits-all social media strategy. The size, budget and complexity of the company will determine the final look and feel of the social media strategy. Companies should experiment with different platforms and approaches to determine the optimal set of platforms and tools. Companies may consider beta testing different platforms as well as conducting social media-related focus groups with their customers and employees. Source: www.download.bg When it comes to social media, companies should keep one eye on mitigating risk through policies, training, etc. and keep the other eye on seeking opportunities that build the company’s brand. 13 Creating an Ironclad Social Media Policy Jesse Torres WHO SHOULD FRAME THE POLICY? Now that the content of the policy has been discussed, it is important to determine who should create the policy. Different companies may approach this differently. However, a strong approach is to involve as many stakeholders as possible in crafting the policy. Marketing and Public Relations Departments The Marketing and Public Relations Departments are responsible for many of the social media related activities. Marketing and PR are usually tasked with creating awareness and interaction with the company’s brand through various marketing and PR efforts. As such, members of these departments should have a say in the policymaking process. Legal and Compliance Departments It is always a good idea to involve the Legal and Compliance Departments in the policymaking process. Certain industries are highly regulated (e.g,, healthcare, brokerage, banking, etc.) and require an expert eye to ensure that mandatory requirements are being met. It is, however, important for these departments to attempt to make the policy as non-threatening as possible. It is also crucial to make the policy easy to read and understand since many employees, particularly the younger employees, may not be fully aware of the jargon and other technical requirements. Customer Service Department Increasingly, social media is being used as another customer service channel. Through social media companies are able to learn of customer service issues, either directly through platforms such as Twitter or indirectly through blog posts and similar means. As such, the Customer Service Department needs to be involved in the policymaking process to ensure that the customer service needs are met. Employees Employees are best suited to comment on what will and will not work from a policy perspective. They are out in the social media universe every day participating with peers and other companies. They are best suited to provide real-world input and suggest alternative solutions. 14 Creating an Ironclad Social Media Policy Jesse Torres DISTINGUISHING BETWEEN COMPANY AND PERSONAL Because the personal social media habits of employees may involve the company’s brand, the policy needs to address those activities. In most cases only a small percentage of employees will be officially tasked with creating company-originated outbound social media messages. However, many employees can be personally involved in responding to messaging, such as comments on review sites, social network sites, etc. In these cases the responses are likely to come from the employees’ personal social media accounts. A practical tip that may assist in developing a comprehensive yet easy to understand policy is to divide the policy into two sections – one that applies to activities related to official company business (e.g., responding to a Twitter post to @Company) and another that addresses personal activities that may affect the company’s brand. Source: buycostumes.com 15 Creating an Ironclad Social Media Policy Jesse Torres USE OF SOCIAL MEDIA TEMPLATES Every social media policy should be tailored to the needs of the company. There is no one-size-fits-all social media strategy and likewise, there is no one-size-fits-all social media policy. However, there is also no need to completely reinvent the wheel. Source: poorrichard.files.wordpress.com Hundreds of social media policies from companies large and small are available on the Internet. These policies provide policymakers with a template from which to begin. It is very useful to identify the social media policies of similarly situated companies. These policies are useful in identifying industry-specific challenges and solutions that provide for a better starting point. While companies should not simply cut and paste some other company’s policy, it is always useful to see how others have managed this process. There are many policies available on the Internet. Hundreds of sample policies are available at www.JesseTorres.com/smpolicies. 16 Creating an Ironclad Social Media Policy Jesse Torres CONCLUSION The purpose of implementing a social media policy is not to “control’ employees. Instead, the idea is to educate employees on the effects (positive and negative) that social media can have on the company. Some argue that the implementation of a social media policy is unnecessary because it calls for controlling the uncontrollable (employees). This is a faulty argument. A policy cannot “control” an employee but it can definitely do a number of things that together can protect the organization. A policy can provide baseline social media knowledge. This baseline knowledge is the information that is necessary to ensure that employees understand how their actions can be detrimental to the organization. A social media policy can also reduce the chance of an employee engaging in an activity that would receive negative publicity. Further, the policy sets the ground rules and holds employees accountable for acting against better judgment and committing a Career Altering Decision. The policy, while authoritative, should also provide employees the room to personalize the messages by speaking in their own voice. While embracing social media does require accepting the loss of some control over the messaging, the potential benefits that are derived from a well thought out social media strategy and policy far outweigh the adverse effects. Ultimately, social media is about acting in a trustworthy fashion. This means honest and transparent interaction that generates goodwill within the user community. It is this goodwill that translates into the bottom line that makes social media worth the effort. Social media simply forces companies to act in a manner that is expected by consumers and that for some reason is rarely seen in business. 17 Creating an Ironclad Social Media Policy Jesse Torres REFERENCE MATERIAL 10 Must-Haves for Your Social Media Policy (Mashable.com) Companies Need a Social Media Policy (Reuters.com) Crafting a Social Media Policy (SFGate.com) How to Write a Social Media Policy (Inc.com) Why Social Media Policies Don't Work (GigaOM.com) 18 Creating an Ironclad Social Media Policy Jesse Torres