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What Should Employee Social Media Policies Stress?
This article first appeared in the Financial
Times Ignites service on September 17,
2010.
Q:
What should mutual fund companies emphasize in designing and implementing policies on their
employees' use of social media tools?
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A:
When it comes to social media and how its use may impact an organization, it is advisable
that financial institutions, including mutual fund complexes, put a comprehensive social
media policy into effect. Such policies should encompass both the corporate use of social
media (as applicable) and the individual's use of social media tools.
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Shaun M. Hassett
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By doing so, all will better know and understand the guidelines and processes to be
followed, as well as the processes in place to address issues that may arise.
Some common guidelines for such policies may include the following:
Remember the Internet is not anonymous, nor does it forget. Each person who posts
a comment, tweet, blog entry or other form of communication is responsible for the content
posted. As the author or poster of social media content, this responsibility is yours and
yours alone. Unless otherwise stated, the social media tools you use are not official
vehicles of your company.
Illegal activities and copyrighted materials. Do not post materials that violate the
privacy rights of others. This may include, but not be limited to, posting of information
that may violate the intellectual property rights or copyright of another, unless you own
the copyright or intellectual property rights in question, or have express written
permission of the copyright or intellectual property rights owner to post such material.
If you have any questions on this, be sure to double-check with compliance and legal
counsel before posting any such materials.
Avoiding hazardous materials. The do-not-do list needs to emphasize the following:
- Do not post materials that are obscene, defamatory, threatening, abusive, hateful,
embarrassing, or harassing to another party.
- Do not post any materials that contain viruses, Trojan horses, worms, or any other
code that may damage, interfere with, serendipitously intercept or expropriate any
system, data or other information.
- Exercise caution regarding exaggeration, colorful language, guesswork, profanity,
legal conclusions, characterizations or other forms of questionable information.
It's also key to identify your affiliation with whatever firm you work for as appropriate.
This helps to provide transparency and mitigate concerns that your posts have a hidden
agenda, or are "below board" in a manner that may hurt your firm.
Protect confidential information. Confidential, proprietary or trade secret
information is strictly off limits for any posts via social media. The only exemptions
would be if the company approved such communications as part of the firm's overall
corporate use of social media tools. This confidential information will include any
details about: the company's dealings, clients, business practices, trade practices,
business strategy, product plans and road maps, revenues or other financial information;
or other information concerning management or business decisions.
The policy's priorities also need to make clear that employees:
- Do not approve recommendations or testimonials in personal posts outside of work
using social media tools.
- Do not offer or appear to offer legal, financial or other professional forms of
advice through any individual posts using social media tools. There are strict
prohibitions on this applicable to both financial firms as well as gatekeepers.
- Do not "return fire." Should another party post a negative comment about the firm
or about you or another person affiliated with the firm, do not respond in kind.
Please consult with compliance and/or internal counsel about such posts. This will
allow your firm's management to respond in an appropriate manner.
While a number of other components may be incorporated into the drafting of such
policies, these are good starting points. It is advised that you also make sure that
your social media policies are in line with other corporate communications policies
as well.
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