How To: Create a Social Media Policy

Are You Ready to Defend Your Brand?

• If you talk to others on social media via company accounts, you must be able to back your statements

• All financial social media activity is now subject to FINRA Regulatory Notice 10-06 compliance.– Other industries are adopting similar regulations; 10-06 is a good

starting point for industries that don't have an established regulatory document

• Critics may attack you for what is said online– Repercussions for small businesses can be devastating– For large businesses, the cost of influence can cripple

What is a Social Media Policy?

• FINRA Regulatory Notice 10-06 states it is “how firms and their registered representatives could use social media sites for legitimate business purposes in a manner that ensures investor protection.”– It will “guide firms on applying the communications rules

to social media sites, such as blogs and social networking sites.”

– “As the use of social media sites increases over time—investors are protected from false or misleading claims and …supervise their associated persons’ participation in these sites.”

A Social Media Policy Is…

• Operating without a social media policy is like driving without a seatbelt; eventually it will cost you, and the consequences could be dire

Keep in Mind…

• An effective social media policy should not shut down social media activity, but rather encourage it

• This policy will limit your business's liability in the event that:– Confidential information is leaked– Subpoena is issued– Ediscovery request comes about

What to Include in a Social Media Policy:

• General business conduct• Employee personal responsibility online• Self identification when participating on 3rd

party site (i.e. someone else’s blog)• Use a disclaimer– “The postings on this site are my own and

don't necessarily represent IBM’s positions, strategies or opinions”

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What to Include in a Social Media Policy:

• Protect proprietary and confidential company information online

• Never cite client or customer references without their approval

• Respect your audience• Always be transparent• Use common sense

Having a Social Media Policy in Place Will Help You…

• Respond appropriately• Have the right message ready when needed• Give strict guidelines of what to and not to do• Outline what can be said about the company online• Disseminate personal social media usage rights while

at work• Explain disclaimer policy required by employees

when discussing the company to others

Remember – They’re Listening

• You always have an audience online– If you send a derogatory tweet, rant about a competitor, or

leave a nasty response on Facebook, it will be seen

• Remain calm and professional online, no matter the situation

• Have a zero tolerance policy • Create the policy in a way that encourages

employees to act proactively and positively engage online

Keep The Records• FINRA requires “every firm that

intends to communicate, or permit its associated persons to communicate, through social media sites must first ensure that it can retain records of those communications as required.”

• Backupify enables firms to retain their records of communications through a social media backup plan. See plans and pricing here.