The expansion of social media in the workplace and for personal use has made it vital for financial institutions to include a specific social media policy within its policies and procedures. In the past it was easier to manage social media use by restricting access to sites on company systems, but smart phones and the acceptance of using social media in marketing communications has changed the landscape. Policies are needed to provide guidance to employees concerning appropriate use and for financial institution’s to manage risk assessment. In addition, the release of the Federal Financial Institutions Examination Council (FFIEC) guidelines has brought even more attention to meeting regulatory requirements.
8 Steps to Create Your Social Media Policy
Financial institutions that may be creating a policy for the first time do not have to reinvent the wheel. Many companies have implemented policies that are available online to assist in getting started. A comprehensive policy can be created using the following steps:
1. Form a Committee – Social media is not just a marketing communications tool, and the policy needs to address several areas that should include representation from marketing, compliance, human resources and upper management.
2. Research and Review– There are many social media policies that are available to use as templates and provide suggestions on what you may want to include in your policy. For your reference, here are links to resources to get started.
3. Select and Prioritize – The specifics in your policy will align with your institution’s culture and values. There is no one-size-fits-all policy and your policy should fit with your other governing documents and employee handbook.
4. Convene the Committee – Committee members can lend their expertise to these specific areas to consider for inclusion:
- define the institution brand presence on social media for marketing purposes
- specify acceptable and unacceptable employee use of social media for business purposes
- use of disclaimers
- follow copyright, fair use and financial disclosure laws
- define who can use social media on behalf of the institution
- define who can speak on behalf of the institution on social media
- define appropriate behavior when using social media in the workplace
- guidance to dealing with negative comments
- describe the types of content that cannot be published, especially in dealing with customer privacy issues
- describe approval and monitoring processes
- specify employee training that may need to be completed
- identify roles and responsibilities for enforcement of the policy
5. Write the First Draft – Present to appropriate management for review. Make any edits based on feedback.
6. Counsel Review – Your legal counsel should provide final review.
7. Present to Board for Approval.
8. Communicate – Implement a plan for employee review and acceptance.
A comprehensive social media policy guides employees on acceptable use, defines social media marketing protocols, and is an important document for regulatory compliance. Social media use and activity will only grow and continue to evolve as technology changes. A proactive approach will allow financial institutions to also adapt and manage change while being mindful of the regulatory environment.
Do you have any examples of social media policies to share or comments to add to the steps above?