Posts on social media made by an employee could be viewed by the public as reflecting the financial institution's official policies, or may otherwise reflect poorly on the financial institution, depending on the form and content of the communications (FFIEC). In other words, your employees can become "accidental influencers" for your brand.
If not managed correctly, employees' social media posts can subject your organization to compliance risk, operational risk, and reputational risk. It's important to establish the appropriate policies and training to address employee participation in social media representing the financial institution.
As part 4 of our social media compliance blog series, learn some of the strategies used by social media experts to help ensure that their employees are utilizing social media appropriately and safely.
Create a Framework For Compliance
Consider providing a framework for employees in which they have the freedom to be creative and spontaneous in their social media posts while still ensuring they are compliant with regulations. This framework can include a list of pre-approved language, hashtags, where to place disclosures, etc.
Creating "categories" for addressing different types of content can be an excellent framework strategy to guide employees on what they can or cannot post. Here's an example of different "tiers" of content used at New York Life:
RED LIGHT CONTENT
Content that is directly out of compliance and can never be posted under any circumstances (confidential or personal information, etc.)
YELLOW LIGHT CONTENT
Content that could be noncompliant if not worded or disclosed properly, and therefore needs a layer of compliance approval (financial standings, products, claims, etc.)
GREEN LIGHT CONTENT
Content that does not need review or approval from compliance (i.e., comments about the weather)
"Using this basic framework, we're able to facilitate [employees] to be authentic and live in the moment and not feel like they have to get compliance's approval for everything." – Dipayan Gupta, New York Life
Hold Internal Compliance Trainings
Conduct regular internal compliance trainings for your employees where you provide updates on current and applicable laws and regulations they should be aware of for their own social media usage.
As part of these trainings, consider providing written guidance documents on how they can speak about your company while still complying with social media regulations, and have these documents easily accessible in a shared folder or document.
|EMPLOYEES CAN SHARE:||EMPLOYEES SHOULD NOT SHARE:|
|How a product has helped them
Talk about the company anecdotally
|Endorsements of the company
Recommendations of products or services
If an employee wants to post about the company or product specifically, take preventative measures by requesting review of any creative of an employee's post before it goes out.
While pre-approving content and providing guidance for employees certainly helpful, it does not always mean that they will be followed to a tee. Monitoring employees' posts (as they pertain to the specific company or product) is the only way to ensure full compliance and to mitigate risk.
This process can be long and labor-intensive, which is why experts turn to technology in order to automate the monitoring and discovery of their brand to catch non-compliant posts in real-time and remediate them quickly.
"By leveraging the power of PerformLine … you can automate the discovery of your brand across Facebook, Twitter, LinkedIn and YouTube to provide a complete, comprehensive view of your social media compliance.” – Tony Paterno, PerformLine
If you would like to learn more about how PerformLine can automate the monitoring and discovery of your brand across social media, speak to one of our experts today.