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Enable Social Networks
So who’s using Social Media? And Why?


     Sales & Marketing
            Promotions
            Advertising
            Branding

     HR
            Background checks
            Recruiting

     Scientists & Researchers
            Information exchange
            Collaboration

     IT
            Investigation of security breaches


A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Social Networking: Balancing Benefit & Risk
    Risks & Challenges

     Employee productivity
    – Control who can access what, when, and for how long

     Content security
    – Introduction of malware

     Brand and reputation protection
    – Allow “approved corporate posters” to self-moderate
    – Moderate posts from unapproved corporate posters

       IP/Information Leak Prevention/NDA compliance
    –   Sensitive, confidential term dictionary matching
    –   Stop contract staff accidentally leaking your secrets
    –   Quarantine posts for moderation by a reviewer
    –   Quick deployment, no desktop touch

       Compliance with regulation (e.g., FINRA, PCI)
    –   Archive content
    –   Stop credit card number patterns
    –   Control specific content
A U V
          Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Web 2.0 & Social Networks Regulation & Compliance



               Regulation                                                        Social Network and Web 2.0 Impact

                                                         Obliged to store records and make accessible. Public correspondence requires
   SEC and FINRA                                         approval, review and retention. Extended to social media.
                                                         http://www.finra.org/Industry/Issues/Advertising/p006118

                                                         Protect information, monitor for sensitive content, and ensure not sent over
   Gramm-Leach-Bliley Act (GLBA)                         public channels (e.g., Twitter)

                                                         Ensuring cardholder data is not sent over unsecured channels AND PROVING
   PCI                                                   IT.

                                                         Prevent identity theft. Protect IM and Web 2.0 from malware and phishing
   Red Flag Rules                                        when users are more likely to drop their guard.


                                                         Email and IM are ESI. Posts to social media sites must be preserved if
   FRCP (eDiscovery)                                     reasonably determined to be discoverable. http://blog.twitter.com/




A U V
         Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Web 2.0 & Social Networks Regulation & Compliance



               Regulation                                                      Social Networks and Web 2.0 Impact

   Sarbanes-Oxley (SOX)                                 Businesses must preserve information relevant to the company reporting.

   Canadian Securities
                                                        Retain records for two years, in a manner that allows “rapid recovery to a
   Administrators National                              regulator,” Can extend to IM and social media.
   Instrument 31-303 (CSA NI)
   Investment Dealers Association                       Demands the retention of records with respect to business activities,
   of Canada (IDA29.7)                                  regardless of its medium of creation.

   MiFID and FSA
                                                        Specifically requires the retention of electronic communications conversations
   Markets in Financial Instruments                     when trades are referenced.
   Directive (EU)
   Model Requirements for the
   management of Electronic                             European requirements for the retention of electronic records.
   Records (MoReq)




A U V
         Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
FINRA Regulatory Notice 10-06:
   Guidelines for Social Networks


                Regulation                                                        Social Network and Web 2.0 Impact

   SEC Rules 17a-3 and 17a-4 and
   NASD Rule 3110                                         Retain records of communications related to business


                                                          Electronic forum & chat rooms, content posted to social media may constitute
   Public Appearances                                     a public appearance

   Prior Approvals                                        Wall postings require prior approvals

   Participation                                          Real-time participation on social networks equals participation

                                                          For instance communications between research and investment banking
   FINRA Regulatory Notice 07-59                          departments should be restricted

                                                          Only those subject to firms supervision should have access, provide training
   Restrict Personnel                                     prior to engagement, prohibit or restrict those who pose a compliance risk.
                                                          Restrict access with technology.




A U V
          Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Financial Services Authority (FSA):
  Guidelines for Social Networks

               Regulation                                                        Social Network and Web 2.0 Impact

   Senior Management
   Arrangements, Systems and
   Controls (SYSC)                                       An enterprise must arrange for orderly records to be kept of its business and
                                                         internal organization.
   SYSC 9.1.1


   SYSC 9.1.2                                            Records must be kept for at least five years.

                                                         An enterprise should have appropriate systems and controls in place with
   SYSC 9.1.5                                            respect to the adequacy of, access to, and the security of its records.

   Policy Statement 08/1                                 Must record conversations on public and enterprise IM networks.
                                                         A firm must take reasonable care to establish and maintain such systems and
   SYSC 3.1                                              controls as are appropriate to its business.
                                                         Firms must take reasonable steps to ensure that ethical walls remain effective
   SYSC 10.2                                             and are adequately monitored.

                                                         All communications or financial promotions must be based on the principles of
   Financial Promotions Industry                         fair dealing. Adequate records of financial promotions must be kept.
   Update No. 5


A U V
         Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Enabling Social Networking: Solution Requirements


                    Issue                                                             Control Requirements

   Identity management                             Ensure that all the different logins of an individual link back to corporate identity

   Activity control                                Posting of content allowed for marketing but read-only for everyone else

   Granular application control                    Employees can access Facebook, but not Facebook Chat or Facebook Games


   Anti-malware                                    Protect network against hidden phishing or Trojan attacks


   Data leak prevention                            Protect organization from employees disclosing sensitive information


   Moderation                                      Messages posted only upon approval by designated officer

   Logging and archiving                           Log all content posted to social networks

   Export of data                                  Export stored data to any email archive or WORM storage




A U V
          Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Social Networking Control: Basic functionality

   Simple SPAN/monitor port deployment to allow/block
  –   Social Networking Widget Usage
  –   Web 2.0 applications (~4,500)                                                                                   LAN/WAN   Internet
  –   Instant messaging (~200)
  –   P2P (~200)
  –   URL filtering
  –   Anti-Malware


                                                                                            Switch




                                                                                               All Internet Traffic
               Users



                                               Active Directory
                                             Group-based policies               Unified Security Gateway
                                                                                     Secure & Enable Web 2.0

A U V
         Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
URL Filtering & Anti-Malware




                 Allow
                 Block
                 Coach
                 Time quotas



A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Social Networking Widget Categorization


                                                                                    – Control access to individual
                                                                                      social media sites
                                                                                    – Allow/block application
                                                                                      widgets on popular sites




A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
SaaS Infrastructure

   • Fully Redundant Architecture
   • End-to-End Failover
   • Fully Redundant and Mirrored Database
   • Extensive Network and Application Monitoring and
     Alerting




A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Social Networking Feature Control




        • Control features or areas of content posting by user or group

A U V
         Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Content Monitoring




                                                                                      Policy summaries
                                                                                      Easy-to-set policies
                                                                                    – Archiving
                                                                                    – Moderation
                                                                                      Lexicons
                                                                                      Actions to take
A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
eDiscovery of Social Networking Posts

        Social networking activity and
        posts are captured




                                                                                      All the captured
                                                                                      events are presented
                                                                                      for eDiscovery and
                                                                                      available for export to
                                                                                      archiving platforms



A U V
          Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Moderation




                                                                                    Posts to Twitter/Facebook/LinkedIn
                                                                                    held for review by the following
                                                                                    criteria:
                                                                             – All
                                                                             – Keyword/dictionary matches
                                                                             – Regular expressions (e.g., credit
                                                                               card/SSN patterns)


A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Simplified Moderator Workflow

                                             STEP 3
                             Moderator receives e-mail                                                              STEP 4
                             notification about pending messages                                •Moderator signs-on to Socialite reviewer console
                                                                                                •Moderator reviews messages and depending
                                                                                                upon appropriateness Approves or Rejects a
                                                                                                message
                                                                                                •Moderator also has an option to leave a review
                         STEP 2                                                                 comment for each post
          Socialite intercepts post and
          provides a notification that
          content is being monitored and
          will be posted only upon approval
          by the moderator

                                                                                                                STEP 5
                                                                                                      Accepted posts are sent to the
                                                                                                      network on behalf of the user



                                                                               STEP 1
                                                              User posts message on Facebook,
                                                              LinkedIn, or Twitter




                                                                                                              STEP 6
                                                                                                Accepted posts are viewed by the user

A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
Moderator work queue & transcript review




   Moderator queue allows bulk
   approve or each post reviewed
   individually.




A U V
        Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
End User Experience




        Toolbar displayed for each
        site, showing user’s post “queues”
        User can click on their queues and
        see a list of the messages




A U V
          Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.

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Actiance enabling social_networks

  • 2. So who’s using Social Media? And Why?  Sales & Marketing  Promotions  Advertising  Branding  HR  Background checks  Recruiting  Scientists & Researchers  Information exchange  Collaboration  IT  Investigation of security breaches A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 3. Social Networking: Balancing Benefit & Risk Risks & Challenges  Employee productivity – Control who can access what, when, and for how long  Content security – Introduction of malware  Brand and reputation protection – Allow “approved corporate posters” to self-moderate – Moderate posts from unapproved corporate posters  IP/Information Leak Prevention/NDA compliance – Sensitive, confidential term dictionary matching – Stop contract staff accidentally leaking your secrets – Quarantine posts for moderation by a reviewer – Quick deployment, no desktop touch  Compliance with regulation (e.g., FINRA, PCI) – Archive content – Stop credit card number patterns – Control specific content A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 4. Web 2.0 & Social Networks Regulation & Compliance Regulation Social Network and Web 2.0 Impact Obliged to store records and make accessible. Public correspondence requires SEC and FINRA approval, review and retention. Extended to social media. http://www.finra.org/Industry/Issues/Advertising/p006118 Protect information, monitor for sensitive content, and ensure not sent over Gramm-Leach-Bliley Act (GLBA) public channels (e.g., Twitter) Ensuring cardholder data is not sent over unsecured channels AND PROVING PCI IT. Prevent identity theft. Protect IM and Web 2.0 from malware and phishing Red Flag Rules when users are more likely to drop their guard. Email and IM are ESI. Posts to social media sites must be preserved if FRCP (eDiscovery) reasonably determined to be discoverable. http://blog.twitter.com/ A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 5. Web 2.0 & Social Networks Regulation & Compliance Regulation Social Networks and Web 2.0 Impact Sarbanes-Oxley (SOX) Businesses must preserve information relevant to the company reporting. Canadian Securities Retain records for two years, in a manner that allows “rapid recovery to a Administrators National regulator,” Can extend to IM and social media. Instrument 31-303 (CSA NI) Investment Dealers Association Demands the retention of records with respect to business activities, of Canada (IDA29.7) regardless of its medium of creation. MiFID and FSA Specifically requires the retention of electronic communications conversations Markets in Financial Instruments when trades are referenced. Directive (EU) Model Requirements for the management of Electronic European requirements for the retention of electronic records. Records (MoReq) A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 6. FINRA Regulatory Notice 10-06: Guidelines for Social Networks Regulation Social Network and Web 2.0 Impact SEC Rules 17a-3 and 17a-4 and NASD Rule 3110 Retain records of communications related to business Electronic forum & chat rooms, content posted to social media may constitute Public Appearances a public appearance Prior Approvals Wall postings require prior approvals Participation Real-time participation on social networks equals participation For instance communications between research and investment banking FINRA Regulatory Notice 07-59 departments should be restricted Only those subject to firms supervision should have access, provide training Restrict Personnel prior to engagement, prohibit or restrict those who pose a compliance risk. Restrict access with technology. A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 7. Financial Services Authority (FSA): Guidelines for Social Networks Regulation Social Network and Web 2.0 Impact Senior Management Arrangements, Systems and Controls (SYSC) An enterprise must arrange for orderly records to be kept of its business and internal organization. SYSC 9.1.1 SYSC 9.1.2 Records must be kept for at least five years. An enterprise should have appropriate systems and controls in place with SYSC 9.1.5 respect to the adequacy of, access to, and the security of its records. Policy Statement 08/1 Must record conversations on public and enterprise IM networks. A firm must take reasonable care to establish and maintain such systems and SYSC 3.1 controls as are appropriate to its business. Firms must take reasonable steps to ensure that ethical walls remain effective SYSC 10.2 and are adequately monitored. All communications or financial promotions must be based on the principles of Financial Promotions Industry fair dealing. Adequate records of financial promotions must be kept. Update No. 5 A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 8. Enabling Social Networking: Solution Requirements Issue Control Requirements Identity management Ensure that all the different logins of an individual link back to corporate identity Activity control Posting of content allowed for marketing but read-only for everyone else Granular application control Employees can access Facebook, but not Facebook Chat or Facebook Games Anti-malware Protect network against hidden phishing or Trojan attacks Data leak prevention Protect organization from employees disclosing sensitive information Moderation Messages posted only upon approval by designated officer Logging and archiving Log all content posted to social networks Export of data Export stored data to any email archive or WORM storage A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 9. Social Networking Control: Basic functionality  Simple SPAN/monitor port deployment to allow/block – Social Networking Widget Usage – Web 2.0 applications (~4,500) LAN/WAN Internet – Instant messaging (~200) – P2P (~200) – URL filtering – Anti-Malware Switch All Internet Traffic Users Active Directory Group-based policies Unified Security Gateway Secure & Enable Web 2.0 A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 10. URL Filtering & Anti-Malware Allow Block Coach Time quotas A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 11. Social Networking Widget Categorization – Control access to individual social media sites – Allow/block application widgets on popular sites A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 12. SaaS Infrastructure • Fully Redundant Architecture • End-to-End Failover • Fully Redundant and Mirrored Database • Extensive Network and Application Monitoring and Alerting A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 13. Social Networking Feature Control • Control features or areas of content posting by user or group A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 14. Content Monitoring Policy summaries Easy-to-set policies – Archiving – Moderation Lexicons Actions to take A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 15. eDiscovery of Social Networking Posts Social networking activity and posts are captured All the captured events are presented for eDiscovery and available for export to archiving platforms A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 16. Moderation Posts to Twitter/Facebook/LinkedIn held for review by the following criteria: – All – Keyword/dictionary matches – Regular expressions (e.g., credit card/SSN patterns) A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 17. Simplified Moderator Workflow STEP 3 Moderator receives e-mail STEP 4 notification about pending messages •Moderator signs-on to Socialite reviewer console •Moderator reviews messages and depending upon appropriateness Approves or Rejects a message •Moderator also has an option to leave a review STEP 2 comment for each post Socialite intercepts post and provides a notification that content is being monitored and will be posted only upon approval by the moderator STEP 5 Accepted posts are sent to the network on behalf of the user STEP 1 User posts message on Facebook, LinkedIn, or Twitter STEP 6 Accepted posts are viewed by the user A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 18. Moderator work queue & transcript review Moderator queue allows bulk approve or each post reviewed individually. A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.
  • 19. End User Experience Toolbar displayed for each site, showing user’s post “queues” User can click on their queues and see a list of the messages A U V Confidential and Proprietary © 2011, Actiance , Inc. All rights reserved.

Notas del editor

  1. Osterman Research conducted a study and found that corporate users spend an average of 18 minutes on a typical workday using social networking tools (or about 4% of their workday). Indeed our own survey showed a change from 2009 to 2010 in the business use of Twitter, going from 13% of users to 78% , a 6-fold increase.Adoption of social computing and social networking in the enterprise is being driven by individuals and departments within the company, such as the Marketing & PR teams who want to use social networking for corporate messaging and advertisements or analysts who wish to publish “market”-relevant data. These are the folks who need write access.Conversely, there are those corporate users that only need read-only access. This could be departments like HR/Compliance/IT Security, which use social media to research new hires or conduct investigations. And then there’s the issue of personal use. We’ve found that restricted personal use is generally OK so long as clear guidelines are made available company-wide.
  2. So now that I’ve set the context for you and discussed the risks and regulations, it might calm your nerves, knowing that controls are available to address these security, management, and compliance concerns.Whether it’s preventing inadvertent or malicious leakage of information through social networks, protecting against hidden phishing or trojan attacks, or mapping the identities of your users across different social networking sites, there are solutions out there that enable you to comply with applicable security and compliance guidelines. For instance, it’s possible to control the activities of organizations, groups, or even individual users by setting policies, such as “only Marketing can post content” or “HR can have only read-only access to LinkedIn”. If the moderation of content is important to you (perhaps if you’re FINRA-regulated), then it’s now possible to have a second pair of eyes reviewing content before it’s posted, with little impact on the end user. And if that content is inappropriate, you can block it. If you want to enable the use of Facebook, LinkedIn, or Twitter, but block the use of thousands of applications within them, then that’s also doable, as is the logging and archiving of all activity and content, so that you have a full picture of the real-time communications of and between your users. At Actiance, we’ve been in the business of real-time communications security, management, and compliance since 2001, so we understand and know how to seamlessly integrate these real-time controls with your existing IT infrastructure.
  3. With respect to the URL filtering and anti-malware features, you can allow or block access to certain categories, such as restaurants, shopping, sports, etc. Coaching is also permitted. This is like telling someone, “You sure you wanna go there?” Facetime also supports time quotas, whereby you can set a policy such that you can limit how much time your employees spend on specific sites. For instance, you can apply a policy that says that Marketing can only spend 30 minutes a day on Facebook.
  4. And applying those controls is simple: from controlling access to more than 1000 social networking sites to incredibly granular control of 40,000 applets on Facebook. We allow you to set controls by category or right down to the individual application. For example, you want to block access to the 150 chat applications on Facebook but allow access to the 2,142 Facebook business applications. No problem. Or perhaps you want to allow access to just 100 of the business apps and not to the other 2,000 or so. That’s possible, too.
  5. In fact, when it comes to Facebook, LinkedIn, and Twitter, there are nearly a hundred different features where controls can be applied. So if you don’t want your CEO using LinkedIn messaging, you can block that. You can stop the compliance team from using Facebook Careers or the HR team from following groups on LinkedIn. You can even make all of LinkedIn read-only, if that floats your boat.
  6. We also enable you to set your policies through easy pointing and clicking. You can choose to either Store, Alert, Block, or Moderate, or any combination of these four controls, for Facebook, LinkedIn, and Twitter. Furthermore, if you don’t have the time or the resources to moderate every single message that passes through the corporate network, you can set up lexicons such that certain keywords or phrases will trigger the system to withhold messages. For instance, if it’s a social security number or credit card number format, you can set a policy so that the system will catch and hold those messages that have that format.
  7. We also capture all the activities and posts of users on Facebook, LinkedIn, and Twitter – in context. So you can see that when Ted tried to share the phrase “I guarantee it”, he was actually talking about the upcoming football game, not an investment suggestion. Moreover, data can be presented for eDiscovery and exported to the archiving platform of your choice.
  8. Moderators can easily navigate through their queue of pending messages through our easy-to-use interface. Moderators have the option to approve or reject in bulk or individually from the Moderator Events page. But, to really appreciate the true value-add of Facetime’s Socialite, you can click on individual ID numbers to see full transcripts in context. We’re able to capture everything on, say, a Facebook page at the moment someone tried to post a comment. This gives the moderator a much more informed basis on which to approve or reject messages. You certainly don’t want to erroneously reject an otherwise-benign message. For example, a message of “I guarantee it” may have been in reference to the upcoming Lakers-Celtics basketball game, not to some stock recommendation. So, being able to review messages in context is incredibly important.