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Community Ebook / June 2012
                                                                                                                              The Building Blocks of a Sound Social Media Policy




                                                            COMMUNITY EBOOK              /   JUNE 2012   /   WWW.RADIAN6.COM /               1 888 6radian




                                                     The Building Blocks of a
                                                    Sound Social Media Policy
Copyright © 2012 - Radian6 Technologies




                                          www.radian6.com
                                          1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		        Copyright © 2012 Radian6 Technologies                           [1]
Community Ebook / June 2012
                                                                                  The Building Blocks of a Sound Social Media Policy




                                                              The Building Blocks of a
                                                              Sound Social Media Policy
                                                              INTRODUCTION:
                                                              Why You Need a Social Media Policy

                                                              CHAPTER 1:
                                                              Individual Responsibility and Liability

                                                              CHAPTER 2:
                                                              Representing the Organization Online and
                                                              Handling Media Inquiries

                                                              CHAPTER 3:
                                                              Respecting Others

                                                              CHAPTER 4:
                                                              Honoring the Confidentiality of Proprietary
                                                              or Internal Information

                                                              CHAPTER 5:
                                                              Obeying Copyright and Fair Use Laws

                                                              CHAPTER 6:
                                                              Industry-Specific Considerations

                                                              CONCLUSION:
                                                              Encouraging Policy Adherence

                                                              APPENDIX:
                                                              Additional Resources




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		      Copyright © 2012 Radian6 Technologies                          [2]
Community Ebook / June 2012
                                                                                 The Building Blocks of a Sound Social Media Policy




         Introduction /
         Why You Need a Social Media Policy
         If you don’t have a social media policy, you’re inviting disaster. If you do, you’re facilitating
         opportunities for employees to strengthen customer relationships, exemplify company
         values, and draw awareness to your products and services.

         Companies need to support and empower employees by arming them with the information
         they need to successfully and appropriately engage on blogs, Facebook, Twitter, and other
         social media channels. Specifying rules and guidelines means staff can be confident about
         engaging without being afraid of doing lasting damage to your brand.

         This book will address all the vital elements of a social media policy, complete with
         examples from different companies so you can create or improve your organization’s very
         own policy. (Please refer to the appendix for the links to the full version of these publicly-
         available policies.)

         Before we discuss specifics, let’s lay the foundation.

         A little disclaimer: this ebook is meant as a helpful introduction and doesn’t constitute legal
         advice.


         Considerations While Crafting
         Identify the Purpose

         Be clear about the purpose of the policy, and what the policy does and does not cover.

         Nordstrom does this nicely in their policy:

         	We encourage approved employees to use social networking/media (Twitter,
           Facebook, Nordstrom.com, etc.) as a way to connect with customers and others
           during working hours. While social networking is fun and valuable, there are some
           risks you should keep in mind when using these tools. In the social media world, the
           lines are blurred between what is public or private, personal or professional.	  	
           	
           We’ve created these social networking/media guidelines for you to follow when
           representing Nordstrom—in the virtual world.

         Additionally, a social media policy is very different from a social media usage guide.
         Although social network best practices are important for employees, you should refer them
         to separate documentation or training materials for specific how-tos.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		     Copyright © 2012 Radian6 Technologies                          [3]
Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Sync with Established Corporate Values

         Your policy should restate company values, and identify how social media can communicate
         those values.

         Here’s Coca-Cola’s:

         	The vision of the Company to achieve sustainable growth online and offline is guided by
           certain shared values that we live by as an organization and as individuals:

              •	LEADERSHIP: The courage to shape a better future;
              •	COLLABORATION: Leveraging our collective genius;
              •	INTEGRITY: Being real;
              •	ACCOUNTABILITY: Recognizing that if it is to be, it’s up to me;
              •	PASSION: Showing commitment in heart and mind;
              •	DIVERSITY: Being as inclusive as our brands; and
              •	QUALITY: Ensuring what we do, we do well.
         Both Coca-Cola and IBM also clearly state that online behavior is governed by the principles
         outlined in their governing Business Conduct Guidelines.

         Get Approval from Legal, IT, HR and the Executive Team

         Involve and collaborate with everyone who will play a role in enforcing the policy from the
         very beginning so all necessary compromises can be made in the early stages.

         This includes your in-house lawyer. She’s your best friend here. Without the help from
         your legal team, your social media policy could end up being unhelpfully broad, improperly
         narrow, or otherwise unable to protect your company in potential litigation.

         Lawyers can also help the company understand the implications of reports like the one
         released by the U.S. National Labor Relations Board in August 2011 to ensure your social
         media policy does not unlawfully prohibit employees from using social media to self-
         organize or discuss wages and working conditions protected under Section 7 of the National
         Labor Relations Act (NLRA).

         There have been two subsequent reports released by the NLRB that explain the outcomes
         of multiple cases involving the lawfulness of social media policies in regards to employee
         working rights. We highly recommend consulting the Appendix for links to read them in full.

         Write in Plain English

         Legal jargon and sophisticated vocabulary doesn’t make for a more effective policy. Simplify
         the language, and write it as if you were talking to a peer in person. Use memorable




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		   Copyright © 2012 Radian6 Technologies                          [4]
Community Ebook / June 2012
                                                                                The Building Blocks of a Sound Social Media Policy




         shortcuts like Farris Timimi’s “12-word Social Media Policy” to help employees remember
         the rules:

         	Don’t Lie, Don’t Pry
           Don’t Cheat, Can’t Delete
           Don’t Steal, Don’t Reveal

         Conform to Your Company Culture

         Your corporate culture will determine the contents, tone and specificity of your policy. If
         a button-down and a tie is the required uniform, the language in your social media policy
         might be more formal than a start-up comprised of flip-flop-wearing, Instagram-addicted
         twenty-somethings.

         Make it as Brief as Possible

         The easier it is to consume over a cup of coffee, the more the policy will get read. Use bullet
         points and headings to draw readers to the critical parts of the policy like Nordstrom did.

         Direct Employees to More Information

         Even if your finalized policy addresses every question imaginable, employees may still need
         more clarity. Let employees know how to get in contact with the right people if they have
         questions or want to make suggestions. Volvo does this well.

         In the following chapters, we’ll discuss the various components of an effective social
         media policy.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		    Copyright © 2012 Radian6 Technologies                          [5]
Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Chapter 1 /
         Individual Responsibility and Liability

         Remind Employees of Responsibility for their Actions
         This clause serves as “a reminder that all employees will be held individually responsible for
         their posts and actions in the social Web and that if they violate the law online, they and not
         the organization are accountable,” notes Chris Barger in The Social Media Strategist (p 125,
         Kindle edition).

         How IBM words it:

         	Use your best judgment. Remember that there are always consequences to what you
           publish. If you’re about to publish something that makes you even the slightest bit
           uncomfortable, review the suggestions above and think about why that is. If you’re
           still unsure, and it is related to IBM business, feel free to discuss it with your manager.
           Ultimately, however, you have sole responsibility for what you post to your blog or
           publish in any form of online social media.


         State Possible Consequences for Policy Violation
         The purpose of the social media policy is not to scare employees to the point they have no
         interest in participating. But employees do need to know the potential impact their online
         behavior could have on the well-being of the company as well as their own. Being upfront
         about possible consequences will make them take it seriously.

         This is a perfect example of when your friends in legal come in handy; they can determine
         what your company can and cannot lawfully enforce.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		   Copyright © 2012 Radian6 Technologies                          [6]
Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Chapter 2 / Representing the Organization Online and
         Handling Media Inquiries

         Provide a Stance on the Separation of a Personal and Professional Presence
         In some industries, having employees keep their personal and professional lives separate
         is important. In the healthcare industry, for example, doctors and nurses are strongly
         discouraged from accepting Facebook friend requests from patients.

         Make it clear where your company stands, and direct employees to more information about
         keeping their personal and professional lives balanced or separated in social media.

         How Mayo Clinic words it:

         	Mayo Clinic strongly discourages “friending” of patients on social media websites.
           Staff in patient care roles generally should not initiate or accept friend requests except
           in unusual circumstances such as the situation where an in-person friendship pre-dates
           the treatment relationship.

         How Volvo words it:

         	The company understands and encourages those employees and associates who
           engage in online social media.

         	Volvo Car Corporation strongly recommends that you use your own name and that
           you are transparent with whom you represent when participating, sharing or writing
           in all online publishing. In online conversation, as well as in all other conversation, you
           are always an ambassador for the company even if you are not acting on behalf of the
           company. When you are acting privately, use your own private email-address (gmail,
           hotmail etc). If you are acting as an appointed corporate spokesperson, you can use
           your corporate (xx@volvocars.com) email address.

         	 you are using social media for private purposes, use the same common sense as you
           If
           would use for private phone calls, i.e. limit them to necessary activities and try to avoid
           such activities during working hours.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		   Copyright © 2012 Radian6 Technologies                          [7]
Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Encourage a Disclaimer
         If employees indicate they work for your company in social media, some people may
         confuse employee opinions with those of the company.

         Avoid any confusion by encouraging employees to use a disclaimer on their personal blogs
         and in their bios on other channels like Twitter, Facebook and Google+.

         How Salesforce words it:

         	 salesforce.com we believe in transparency and openness. This means that you do
           At
           not contribute anonymously or under a pseudonym unless it’s your company nickname.
           You must disclose that you work for salesforce.com. On sites like Twitter or Blogger,
           your bio must show your role and affiliation with salesforce.com. You are representing
           the company even though you are not serving as an official voice of the Company. You
           must include a disclaimer that the views you’re expressing are your own and not those
           of salesforce.com.


         Explain How to Handle the Media
         The policy should also include a statement of how to respond if the media approaches an
         employee who is unauthorized to speak on behalf of the organization. This usually involves
         directing the media to the authorized personnel.

         How Nordstrom words it:

         	 a member of the media or a financial analyst contacts you, as always, refer them
           If
           to the PR or Investor Relations team through your store operator. If you have any
           questions about what is considered confidential, check in with your manager or
           Human Resources.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		   Copyright © 2012 Radian6 Technologies                          [8]
Community Ebook / June 2012
                                                                                The Building Blocks of a Sound Social Media Policy




         Chapter 3 /
         Respecting Others
         This section of the policy reminds employees to always be respectful to others on
         social media channels, especially when communicating with coworkers, talking about
         competitors, or conversing with existing or potential customers.

         For safety reasons, discourage employees from sharing other’s personal information such
         as current location, schedules, email addresses and phone numbers. Encourage employees
         to respect one another by requesting they ask each other permission before posting their
         picture or anything about them online.

         Let employees know that it’s okay to disagree with other employees, but encourage them
         not to use their personal blogs or other social profiles to express their differences.


         Include Prohibitions on Hate Speech and Ethnic Slurs
         Hate speech is any communication that threatens, insults or ridicules any person or groups
         based on their race, religion, gender, disability, or other characteristic. It’s illegal in many
         countries, and can expose employers to criminal or civil penalties.

         This section of the policy should strongly discourage employees from using such offensive
         language or initiating personal attacks.

         However, a heavy-handed squashing of free speech can generate backlash as well, making
         your company appear overly controlling. Employees shouldn’t be forbidden from engaging
         in political, religious or social debate, as long as it’s conducted respectfully.

         Clearly defining and prohibiting hate speech can prevent discrimination, damage to your
         brand’s reputation, and impaired customer relations.

         How Salesforce words it:

         Respecting others is addressed in this Salesforce social media policy video.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		    Copyright © 2012 Radian6 Technologies                          [9]
Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Chapter 4 /
         Honoring the Confidentiality of Proprietary or
         Internal Information

         Include Privacy Reminders
         In the words of social media strategist and author, Christopher Barger, your social media
         policy must include “a privacy reminder that the Internet is forever and that whatever gets
         posted is usually searchable and findable by someone, so employees should exercise
         discretion in what they post” (Barger 126).

         To prevent potential lawsuits, set clear boundaries around what information is private
         versus public, and be specific in your definition. In the U.S., any prohibited discussion must
         make exceptions for activities protected under Section 7 of the NLRA.

         Confidential or private information might include:

              •	Product releases and updates
              •	Acquisitions
              •	Internal financials and forecasts
              •	Proprietary product knowledge or trade secrets
              •	Private employee HR information
              •	Employee and customer contact information
              •	Ongoing legal cases

         How Nordstrom words it:		

         	 not publish, post or release information that is considered confidential or not
           Do
           public. If it seems confidential, it probably is. Online “conversations” are never private!
           Do not discuss numbers and other sales figures (non-public financial or operational
           information), strategies and forecasts, legal issues or future promotions/activities. Do
           not post any merchandise pricing information or comparisons.

         How Volvo words it:

         	Volvo Car Corporation’s relationship with our customers, employees and partners is
           our most important asset, and it is important that we always protect this relationship.
           You cannot cite or disclose customer names without their approval. Protect your
           fellow workers and our customers, dealers, and vendors by refraining from sharing




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Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




               any of their personal information, statements, or photographs unless you have their
               written permission to do so. Bringing someone else into the conversation without their
               permission can be destructive to relationships, cause misunderstanding, or violate the
               law (including privacy and defamation laws), commercial contracts, or confidentiality
               agreements.




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Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Chapter 5 /
         Obeying Copyright and Fair Use Laws
         Remind employees to look for and understand the copyrights for images, video, music or
         documents on the Internet before including in a social media post. Look for images that
         are under a Creative Commons license, purchase stock photos with limited use rights, or
         request permission from the copyright holder.

         It’s additionally important to understand the rights of written content online. Just because
         you found it on Google does not make it free. Using short excerpts of content with a link
         to the original piece is generally accepted, but it’s a good idea to get permission for long
         quotes or excerpts.

         How Coca-Cola words it:

         	Give credit where credit is due and don’t violate others’ rights. DO NOT claim
           authorship of something that is not yours. If you are using another party’s content, make
           certain that they are credited for it in your post and that they approve of you utilizing
           their content. Do not use the copyrights, trademarks, publicity rights, or other rights of
           others without the necessary permissions of the rightsholder(s).

         	Respect of copyrights, trademarks, rights of publicity, and other third party rights in the
           online social media space, including with regard to user generated content (UGC). How
           exactly you do this may depend on your particular situation, so work with your cross
           functional teams to make informed, appropriate decisions.




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Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Chapter 6 /
         Industry-Specific Considerations
         Your industry may have specific legal or regulatory obligations that your policy must take
         into account.

         To illustrate:

              •	Expressing impartiality toward political and religious parties is of utmost importance
                for some news publications.
              •	Protecting patient information in social media is vital for healthcare providers.
              •	Compliance, record-keeping and security are critical for the finance industry.
              •	Automakers are required to disclose certain consumer safety information under the
                Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act.

         How the Affinity Health System words it:

         	Remember, disclosing confidential patient Protected Health Information (PHI) in an
           inappropriate manner is a federal offense. The penalties include significant fines and/
           or arrest. Ministry employees should never publicly make comments about the care
           of a specific patient, especially online. Even acknowledging the care of a patient is an
           unacceptable disclosure of PHI.

         How the BBC words it:

         	Impartiality is a particular concern for those working in News and Current Affairs. Nothing
           should appear on their personal blogs or microblogs which undermines the integrity or
           impartiality of the BBC. For example, News and Current Affairs staff should not:

              •	advocate support for a particular political party;
              •	express views for or against any policy which is a matter of current party
                 political debate;
              •	advocate any particular position on an issue of current public controversy or debate.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		   Copyright © 2012 Radian6 Technologies                          [ 13 ]
Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Conclusion /
         Encouraging Policy Adherence
         After working so hard on a company social media policy, you’ll want to take the necessary
         steps to make sure it actually gets read and adhered to.

         Here are a few tips to help make your social media policy a successful one:


         Incorporate it into Employee Training
         The policy isn’t effective until understood by all employees, and that comes with training.
         To minimize unanswered questions, use specific examples to illustrate do’s and don’ts.
         Addressing what is acceptable is just as important as demonstrating what’s not going to fly.


         Make it Accessible
         Post the social media policy to the company intranet or social network, save it to the
         desktop of company-issued computers, or place it on your organization’s shared drive.
         You want the policy to be easily found when an employee’s in doubt. In the interests of
         transparency and accountability, consider sharing it externally by placing it on your website.


         Repackage and Remind
         Repackaging written excerpts into bite-sized tips, internal blog posts, short videos, or
         regular email reminders can keep the social media policy top of mind. The social media
         team at Salesforce used video and presentation slides to make the social media policy more
         interactive, accessible and shareable.

         Humor’s not a bad idea either. To remind our employees how to be respectful, our Director
         of Community and Social Strategy, David B. Thomas, wrote a few fictional tweets and
         posted them to Chatter, our internal social network.

         	No: @BigAirline You’ve stranded me again! Why do I keep flying with you?!
           Never again!
           Yes: @BigAirline I’m stuck in Tuba City and need to get to Pflugerville. Anything you
           can do to help?

         	




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Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         	No: @BigRetailer The idiots in your Poughkeepsie store can’t fix my flange arrestor. I
            want my money back!
            Yes: @BigRetailer My flange arrestor is decombining at 25Mhz. Any suggestions or
            online resources?

         	No: @BigCPGBrand I can’t believe I paid $42 for an electric kazoo and it doesn’t have a
           spit valve! What a ripoff!
           Yes: @BigCPGBrand You know what would make the XR50 Electric Kazoo perfect? A
           spit valve. #thingsthatneedspitvalves


         Revise as Needed
         Business goals and processes can change. So does the popularity and functionality of social
         networks. Your policies should adapt to ensure they continue to cover all the bases.


         Regularly Review Employee Accounts for Compliance
         Have the social media team in your company keep their eyes and ears on the way
         employees are talking about your company online using a social media monitoring tool, and
         ensure someone is responsible for occasionally auditing the way company information is
         listed on employee social network accounts.

         Once you have your social media policy written and adopted, everyone across the company
         can stop worrying about accidentally embarrassing the company, and instead feel the
         freedom to explore the wonderful world of social media.




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		   Copyright © 2012 Radian6 Technologies                          [ 15 ]
Community Ebook / June 2012
                                                                               The Building Blocks of a Sound Social Media Policy




         Appendix /
         Additional Resources

         Templates
              •	Eric Schwartzman’s Social Media Policy Template
              •	WOMMA Social Media Policy Template
              •	SocialFresh Template

         Additional Reading
              •	10 Tips for Creating a Social Media Policy for Your Business
              •	How to Write a Social Media Usage Policy for Your Business
              •	Writing a Social Media Policy
              •	Are You Disclosing? What You Need to Know about FTC Rules and Social Media
              •	Is Your Social Networking Policy Illegal?
              •	U.S. NLRB Report of the Acting General Counsel Concerning Social Media Cases - August, 2011
              •	U.S. NLRB Report of the Acting General Counsel Concerning Social Media Cases - January, 2012
              •	 U.S. NLRB Report of the Acting General Counsel Concerning Social Media Cases - May, 2012

         Social Media Policies
              •	Salesforce
              •	Dell
              •	Clemson University
              •	Mayo Clinic
              •	Southwest
              •	Volvo
              •	Nordstrom
              •	BBC
              •	Coca-Cola

         Questions, comments or feedback for us? Please get in touch. We’d love to hear from you.

         Find us on the web: www.radian6.com
         Follow us on Twitter: www.twitter.com/radian6
         Read the Blog: www.radian6.com/blog
                                                                                                      Author: Shannon Johnson
                                                                                                                Editor: Bart Byl
                                                                                                         Designer: Lise Hansen




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1 888 6RADIAN 1 888 672-3426   /   community@radian6.com 		   Copyright © 2012 Radian6 Technologies                          [ 16 ]

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Building Blocks of a Sound Social Media Policy

  • 1. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy COMMUNITY EBOOK / JUNE 2012 / WWW.RADIAN6.COM / 1 888 6radian The Building Blocks of a Sound Social Media Policy Copyright © 2012 - Radian6 Technologies www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [1]
  • 2. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy The Building Blocks of a Sound Social Media Policy INTRODUCTION: Why You Need a Social Media Policy CHAPTER 1: Individual Responsibility and Liability CHAPTER 2: Representing the Organization Online and Handling Media Inquiries CHAPTER 3: Respecting Others CHAPTER 4: Honoring the Confidentiality of Proprietary or Internal Information CHAPTER 5: Obeying Copyright and Fair Use Laws CHAPTER 6: Industry-Specific Considerations CONCLUSION: Encouraging Policy Adherence APPENDIX: Additional Resources www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [2]
  • 3. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Introduction / Why You Need a Social Media Policy If you don’t have a social media policy, you’re inviting disaster. If you do, you’re facilitating opportunities for employees to strengthen customer relationships, exemplify company values, and draw awareness to your products and services. Companies need to support and empower employees by arming them with the information they need to successfully and appropriately engage on blogs, Facebook, Twitter, and other social media channels. Specifying rules and guidelines means staff can be confident about engaging without being afraid of doing lasting damage to your brand. This book will address all the vital elements of a social media policy, complete with examples from different companies so you can create or improve your organization’s very own policy. (Please refer to the appendix for the links to the full version of these publicly- available policies.) Before we discuss specifics, let’s lay the foundation. A little disclaimer: this ebook is meant as a helpful introduction and doesn’t constitute legal advice. Considerations While Crafting Identify the Purpose Be clear about the purpose of the policy, and what the policy does and does not cover. Nordstrom does this nicely in their policy: We encourage approved employees to use social networking/media (Twitter, Facebook, Nordstrom.com, etc.) as a way to connect with customers and others during working hours. While social networking is fun and valuable, there are some risks you should keep in mind when using these tools. In the social media world, the lines are blurred between what is public or private, personal or professional. We’ve created these social networking/media guidelines for you to follow when representing Nordstrom—in the virtual world. Additionally, a social media policy is very different from a social media usage guide. Although social network best practices are important for employees, you should refer them to separate documentation or training materials for specific how-tos. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [3]
  • 4. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Sync with Established Corporate Values Your policy should restate company values, and identify how social media can communicate those values. Here’s Coca-Cola’s: The vision of the Company to achieve sustainable growth online and offline is guided by certain shared values that we live by as an organization and as individuals: • LEADERSHIP: The courage to shape a better future; • COLLABORATION: Leveraging our collective genius; • INTEGRITY: Being real; • ACCOUNTABILITY: Recognizing that if it is to be, it’s up to me; • PASSION: Showing commitment in heart and mind; • DIVERSITY: Being as inclusive as our brands; and • QUALITY: Ensuring what we do, we do well. Both Coca-Cola and IBM also clearly state that online behavior is governed by the principles outlined in their governing Business Conduct Guidelines. Get Approval from Legal, IT, HR and the Executive Team Involve and collaborate with everyone who will play a role in enforcing the policy from the very beginning so all necessary compromises can be made in the early stages. This includes your in-house lawyer. She’s your best friend here. Without the help from your legal team, your social media policy could end up being unhelpfully broad, improperly narrow, or otherwise unable to protect your company in potential litigation. Lawyers can also help the company understand the implications of reports like the one released by the U.S. National Labor Relations Board in August 2011 to ensure your social media policy does not unlawfully prohibit employees from using social media to self- organize or discuss wages and working conditions protected under Section 7 of the National Labor Relations Act (NLRA). There have been two subsequent reports released by the NLRB that explain the outcomes of multiple cases involving the lawfulness of social media policies in regards to employee working rights. We highly recommend consulting the Appendix for links to read them in full. Write in Plain English Legal jargon and sophisticated vocabulary doesn’t make for a more effective policy. Simplify the language, and write it as if you were talking to a peer in person. Use memorable www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [4]
  • 5. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy shortcuts like Farris Timimi’s “12-word Social Media Policy” to help employees remember the rules: Don’t Lie, Don’t Pry Don’t Cheat, Can’t Delete Don’t Steal, Don’t Reveal Conform to Your Company Culture Your corporate culture will determine the contents, tone and specificity of your policy. If a button-down and a tie is the required uniform, the language in your social media policy might be more formal than a start-up comprised of flip-flop-wearing, Instagram-addicted twenty-somethings. Make it as Brief as Possible The easier it is to consume over a cup of coffee, the more the policy will get read. Use bullet points and headings to draw readers to the critical parts of the policy like Nordstrom did. Direct Employees to More Information Even if your finalized policy addresses every question imaginable, employees may still need more clarity. Let employees know how to get in contact with the right people if they have questions or want to make suggestions. Volvo does this well. In the following chapters, we’ll discuss the various components of an effective social media policy. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [5]
  • 6. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Chapter 1 / Individual Responsibility and Liability Remind Employees of Responsibility for their Actions This clause serves as “a reminder that all employees will be held individually responsible for their posts and actions in the social Web and that if they violate the law online, they and not the organization are accountable,” notes Chris Barger in The Social Media Strategist (p 125, Kindle edition). How IBM words it: Use your best judgment. Remember that there are always consequences to what you publish. If you’re about to publish something that makes you even the slightest bit uncomfortable, review the suggestions above and think about why that is. If you’re still unsure, and it is related to IBM business, feel free to discuss it with your manager. Ultimately, however, you have sole responsibility for what you post to your blog or publish in any form of online social media. State Possible Consequences for Policy Violation The purpose of the social media policy is not to scare employees to the point they have no interest in participating. But employees do need to know the potential impact their online behavior could have on the well-being of the company as well as their own. Being upfront about possible consequences will make them take it seriously. This is a perfect example of when your friends in legal come in handy; they can determine what your company can and cannot lawfully enforce. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [6]
  • 7. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Chapter 2 / Representing the Organization Online and Handling Media Inquiries Provide a Stance on the Separation of a Personal and Professional Presence In some industries, having employees keep their personal and professional lives separate is important. In the healthcare industry, for example, doctors and nurses are strongly discouraged from accepting Facebook friend requests from patients. Make it clear where your company stands, and direct employees to more information about keeping their personal and professional lives balanced or separated in social media. How Mayo Clinic words it: Mayo Clinic strongly discourages “friending” of patients on social media websites. Staff in patient care roles generally should not initiate or accept friend requests except in unusual circumstances such as the situation where an in-person friendship pre-dates the treatment relationship. How Volvo words it: The company understands and encourages those employees and associates who engage in online social media. Volvo Car Corporation strongly recommends that you use your own name and that you are transparent with whom you represent when participating, sharing or writing in all online publishing. In online conversation, as well as in all other conversation, you are always an ambassador for the company even if you are not acting on behalf of the company. When you are acting privately, use your own private email-address (gmail, hotmail etc). If you are acting as an appointed corporate spokesperson, you can use your corporate (xx@volvocars.com) email address. you are using social media for private purposes, use the same common sense as you If would use for private phone calls, i.e. limit them to necessary activities and try to avoid such activities during working hours. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [7]
  • 8. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Encourage a Disclaimer If employees indicate they work for your company in social media, some people may confuse employee opinions with those of the company. Avoid any confusion by encouraging employees to use a disclaimer on their personal blogs and in their bios on other channels like Twitter, Facebook and Google+. How Salesforce words it: salesforce.com we believe in transparency and openness. This means that you do At not contribute anonymously or under a pseudonym unless it’s your company nickname. You must disclose that you work for salesforce.com. On sites like Twitter or Blogger, your bio must show your role and affiliation with salesforce.com. You are representing the company even though you are not serving as an official voice of the Company. You must include a disclaimer that the views you’re expressing are your own and not those of salesforce.com. Explain How to Handle the Media The policy should also include a statement of how to respond if the media approaches an employee who is unauthorized to speak on behalf of the organization. This usually involves directing the media to the authorized personnel. How Nordstrom words it: a member of the media or a financial analyst contacts you, as always, refer them If to the PR or Investor Relations team through your store operator. If you have any questions about what is considered confidential, check in with your manager or Human Resources. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [8]
  • 9. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Chapter 3 / Respecting Others This section of the policy reminds employees to always be respectful to others on social media channels, especially when communicating with coworkers, talking about competitors, or conversing with existing or potential customers. For safety reasons, discourage employees from sharing other’s personal information such as current location, schedules, email addresses and phone numbers. Encourage employees to respect one another by requesting they ask each other permission before posting their picture or anything about them online. Let employees know that it’s okay to disagree with other employees, but encourage them not to use their personal blogs or other social profiles to express their differences. Include Prohibitions on Hate Speech and Ethnic Slurs Hate speech is any communication that threatens, insults or ridicules any person or groups based on their race, religion, gender, disability, or other characteristic. It’s illegal in many countries, and can expose employers to criminal or civil penalties. This section of the policy should strongly discourage employees from using such offensive language or initiating personal attacks. However, a heavy-handed squashing of free speech can generate backlash as well, making your company appear overly controlling. Employees shouldn’t be forbidden from engaging in political, religious or social debate, as long as it’s conducted respectfully. Clearly defining and prohibiting hate speech can prevent discrimination, damage to your brand’s reputation, and impaired customer relations. How Salesforce words it: Respecting others is addressed in this Salesforce social media policy video. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [9]
  • 10. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Chapter 4 / Honoring the Confidentiality of Proprietary or Internal Information Include Privacy Reminders In the words of social media strategist and author, Christopher Barger, your social media policy must include “a privacy reminder that the Internet is forever and that whatever gets posted is usually searchable and findable by someone, so employees should exercise discretion in what they post” (Barger 126). To prevent potential lawsuits, set clear boundaries around what information is private versus public, and be specific in your definition. In the U.S., any prohibited discussion must make exceptions for activities protected under Section 7 of the NLRA. Confidential or private information might include: • Product releases and updates • Acquisitions • Internal financials and forecasts • Proprietary product knowledge or trade secrets • Private employee HR information • Employee and customer contact information • Ongoing legal cases How Nordstrom words it: not publish, post or release information that is considered confidential or not Do public. If it seems confidential, it probably is. Online “conversations” are never private! Do not discuss numbers and other sales figures (non-public financial or operational information), strategies and forecasts, legal issues or future promotions/activities. Do not post any merchandise pricing information or comparisons. How Volvo words it: Volvo Car Corporation’s relationship with our customers, employees and partners is our most important asset, and it is important that we always protect this relationship. You cannot cite or disclose customer names without their approval. Protect your fellow workers and our customers, dealers, and vendors by refraining from sharing www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [ 10 ]
  • 11. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy any of their personal information, statements, or photographs unless you have their written permission to do so. Bringing someone else into the conversation without their permission can be destructive to relationships, cause misunderstanding, or violate the law (including privacy and defamation laws), commercial contracts, or confidentiality agreements. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [ 11 ]
  • 12. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Chapter 5 / Obeying Copyright and Fair Use Laws Remind employees to look for and understand the copyrights for images, video, music or documents on the Internet before including in a social media post. Look for images that are under a Creative Commons license, purchase stock photos with limited use rights, or request permission from the copyright holder. It’s additionally important to understand the rights of written content online. Just because you found it on Google does not make it free. Using short excerpts of content with a link to the original piece is generally accepted, but it’s a good idea to get permission for long quotes or excerpts. How Coca-Cola words it: Give credit where credit is due and don’t violate others’ rights. DO NOT claim authorship of something that is not yours. If you are using another party’s content, make certain that they are credited for it in your post and that they approve of you utilizing their content. Do not use the copyrights, trademarks, publicity rights, or other rights of others without the necessary permissions of the rightsholder(s). Respect of copyrights, trademarks, rights of publicity, and other third party rights in the online social media space, including with regard to user generated content (UGC). How exactly you do this may depend on your particular situation, so work with your cross functional teams to make informed, appropriate decisions. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [ 12 ]
  • 13. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Chapter 6 / Industry-Specific Considerations Your industry may have specific legal or regulatory obligations that your policy must take into account. To illustrate: • Expressing impartiality toward political and religious parties is of utmost importance for some news publications. • Protecting patient information in social media is vital for healthcare providers. • Compliance, record-keeping and security are critical for the finance industry. • Automakers are required to disclose certain consumer safety information under the Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act. How the Affinity Health System words it: Remember, disclosing confidential patient Protected Health Information (PHI) in an inappropriate manner is a federal offense. The penalties include significant fines and/ or arrest. Ministry employees should never publicly make comments about the care of a specific patient, especially online. Even acknowledging the care of a patient is an unacceptable disclosure of PHI. How the BBC words it: Impartiality is a particular concern for those working in News and Current Affairs. Nothing should appear on their personal blogs or microblogs which undermines the integrity or impartiality of the BBC. For example, News and Current Affairs staff should not: • advocate support for a particular political party; • express views for or against any policy which is a matter of current party political debate; • advocate any particular position on an issue of current public controversy or debate. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [ 13 ]
  • 14. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Conclusion / Encouraging Policy Adherence After working so hard on a company social media policy, you’ll want to take the necessary steps to make sure it actually gets read and adhered to. Here are a few tips to help make your social media policy a successful one: Incorporate it into Employee Training The policy isn’t effective until understood by all employees, and that comes with training. To minimize unanswered questions, use specific examples to illustrate do’s and don’ts. Addressing what is acceptable is just as important as demonstrating what’s not going to fly. Make it Accessible Post the social media policy to the company intranet or social network, save it to the desktop of company-issued computers, or place it on your organization’s shared drive. You want the policy to be easily found when an employee’s in doubt. In the interests of transparency and accountability, consider sharing it externally by placing it on your website. Repackage and Remind Repackaging written excerpts into bite-sized tips, internal blog posts, short videos, or regular email reminders can keep the social media policy top of mind. The social media team at Salesforce used video and presentation slides to make the social media policy more interactive, accessible and shareable. Humor’s not a bad idea either. To remind our employees how to be respectful, our Director of Community and Social Strategy, David B. Thomas, wrote a few fictional tweets and posted them to Chatter, our internal social network. No: @BigAirline You’ve stranded me again! Why do I keep flying with you?! Never again! Yes: @BigAirline I’m stuck in Tuba City and need to get to Pflugerville. Anything you can do to help? www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [ 14 ]
  • 15. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy No: @BigRetailer The idiots in your Poughkeepsie store can’t fix my flange arrestor. I want my money back! Yes: @BigRetailer My flange arrestor is decombining at 25Mhz. Any suggestions or online resources? No: @BigCPGBrand I can’t believe I paid $42 for an electric kazoo and it doesn’t have a spit valve! What a ripoff! Yes: @BigCPGBrand You know what would make the XR50 Electric Kazoo perfect? A spit valve. #thingsthatneedspitvalves Revise as Needed Business goals and processes can change. So does the popularity and functionality of social networks. Your policies should adapt to ensure they continue to cover all the bases. Regularly Review Employee Accounts for Compliance Have the social media team in your company keep their eyes and ears on the way employees are talking about your company online using a social media monitoring tool, and ensure someone is responsible for occasionally auditing the way company information is listed on employee social network accounts. Once you have your social media policy written and adopted, everyone across the company can stop worrying about accidentally embarrassing the company, and instead feel the freedom to explore the wonderful world of social media. www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [ 15 ]
  • 16. Community Ebook / June 2012 The Building Blocks of a Sound Social Media Policy Appendix / Additional Resources Templates • Eric Schwartzman’s Social Media Policy Template • WOMMA Social Media Policy Template • SocialFresh Template Additional Reading • 10 Tips for Creating a Social Media Policy for Your Business • How to Write a Social Media Usage Policy for Your Business • Writing a Social Media Policy • Are You Disclosing? What You Need to Know about FTC Rules and Social Media • Is Your Social Networking Policy Illegal? • U.S. NLRB Report of the Acting General Counsel Concerning Social Media Cases - August, 2011 • U.S. NLRB Report of the Acting General Counsel Concerning Social Media Cases - January, 2012 • U.S. NLRB Report of the Acting General Counsel Concerning Social Media Cases - May, 2012 Social Media Policies • Salesforce • Dell • Clemson University • Mayo Clinic • Southwest • Volvo • Nordstrom • BBC • Coca-Cola Questions, comments or feedback for us? Please get in touch. We’d love to hear from you. Find us on the web: www.radian6.com Follow us on Twitter: www.twitter.com/radian6 Read the Blog: www.radian6.com/blog Author: Shannon Johnson Editor: Bart Byl Designer: Lise Hansen www.radian6.com 1 888 6RADIAN 1 888 672-3426 / community@radian6.com Copyright © 2012 Radian6 Technologies [ 16 ]