Creating an Ironclad Social Media Policy by Jesse_Torres

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									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) ( and
                          Community Banker’s Guide to Hispanic Marketing (January
                          2005) (

                          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
                          He      can       also     be       found  on     LinkedIn

                          Download a copy of this ebook at

                          To receive updates to this whitepaper and notices of new related
                          whitepapers,              send             an              email

                            Comments, corrections and other feedback may be sent to the
                                      author at

                             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

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

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.


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
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.

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.

Creating an Ironclad Social Media Policy                                     Jesse Torres

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.


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.

Creating an Ironclad Social Media Policy                                     Jesse Torres

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.

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 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

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.

Creating an Ironclad Social Media Policy                                                         Jesse Torres

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.


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.

Creating an Ironclad Social Media Policy                                        Jesse Torres

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


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.

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


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
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.


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.


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
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.


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
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.


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

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.


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.

Creating an Ironclad Social Media Policy                                       Jesse Torres

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.


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.

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 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.

Creating an Ironclad Social Media Policy                                     Jesse Torres

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.


Creating an Ironclad Social Media Policy                                        Jesse Torres

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.


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

Creating an Ironclad Social Media Policy                                         Jesse Torres

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.

Creating an Ironclad Social Media Policy                                     Jesse Torres
                               REFERENCE MATERIAL

    10 Must-Haves for Your Social Media Policy (

    Companies Need a Social Media Policy (

    Crafting a Social Media Policy (

    How to Write a Social Media Policy (

    Why Social Media Policies Don't Work (

Creating an Ironclad Social Media Policy                        Jesse Torres

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