Social Media Policy: A Worthwhile Investment
As an advisor, chances are you can practically draft an investment policy statement (IPS) in your sleep. But, where do you stand on a social media policy statement? Do you even have one in place?
At a recent networking event, I was involved in a conversation with a professional who talked about his newly distributed, official social media policy. I asked how he intended to execute his plan amongst his employees; that question was met with a blank stare. Perhaps he believed establishing the policy was the finish line; however that is just the beginning.
Here’s the reality: Just as you wouldn’t write an IPS and then dismiss the importance of ongoing monitoring, a social media policy needs oversight, archiving, and ongoing change to be truly effective. FINRA regulations require financial industry professionals to be diligent in company and employee online conduct. Now is the time to get a social media policy written and implemented, if you haven’t already.
Your social media policy must be a living document with input from your employees. This document will outline the dos and don’ts of online activity to protect you and your company as well as your staff. Be sure your policy contains specific language defining what is included under the social media umbrella. With so many platforms and applications today, clarity cannot be overdone. Generally, a social media policy should outline rules related to the areas of confidentiality, privacy, ethics, competitors, and fair use; the goal is to establish appropriate-use guidelines. Consult an industry-versed attorney for professional guidance specific to your company.
Monitor the Situation
Monitoring of employee and company social media activity is a non-negotiable must. Be upfront with employees. Let them know exactly how their content is being observed and the reasons why. An act as seemingly innocuous as endorsing on LinkedIn, liking a post or page on Facebook, or retweeting on Twitter can be considered a company testimonial. Monitoring employee online activity isn’t a no-confidence vote; it’s a requirement that’s necessary to evaluate your company’s compliance in the social media realm.
Alternatively, taking a more hands-off approach by hiring a designated social media compliance officer or using one of the emerging industry-specific monitoring software applications are options. There is no one-size-fits-all solution, but there are many choices available for your business needs.
Lock and Key
Federal regulators require that every shred of social media activity generated by financial services institutions is archived for three years. That’s a daunting task. It may be helpful to look into a provider such as Smarsh , which specializes in archiving.
Feed the Mind
If your employees help draft your social media policy, you’ve already got a leg up on education. A Lunch and Learn is an excellent way to engage employees in a relaxed setting. Social media is always evolving. Education doesn’t need to feel cumbersome and time consuming, but plan for regular updates.
A social media policy protects your firm, your employees, and you from liability. Putting social media-use guidelines in writing is a vitally important step to take in this Digital Age. It ensures everyone within your firm is on the same page and that you are fulfilling the rules and regulations required by FINRA.