2. 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
3. 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.”
4. 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
5. 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
6. 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”
• (continued on next page)
7. 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
8. 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
9. 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
10. 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.