Imagine this: your company spent $5 million for a 30-second ad that aired during the Super Bowl. Early reaction was overwhelmingly positive, but then you wake up the next morning to hear that a damaging video of one of your executives has gone viral overnight, attracting millions of views. Someone posted a cell phone video of him ridiculing the intelligence of customers who pay for your services. The language is sufficiently colorful to have caught the attention of traditional news outlets, and the video has already been featured on morning news shows. Angry customers are starting to phone, email, and post comments on social media. A member of the board of directors has called demanding an explanation. Which will have the greater impact – the carefully crafted ad or the unscripted, unauthorized video?
Social media is pervasive and powerful. Your firm can embrace it or try to ignore it, but the impact of social media on a firm’s reputation seems inevitable. How does one manage the risks associated with social media while enjoying the rewards of a robust social media presence? This article examines some social media policies to help manage the risks.
First, recognize that you will need two policies. If your firm has an “official” social media presence (whether Facebook, Twitter, or some other platform), it will need policies to guide content creators. Beyond that, many, if not most, members of the firm participate in some form of social media. That could include blogs, video posts, and media interviews that could link back to the firm. Policies need to be in place to establish expectations about social media content that refers to the firm, its products and services, and its employees, while also recognizing employees’ rights to free speech. Before developing social media policies, consult with human resources and legal counsel. There could be legal implications if policies intrude on employees’ personal online space.
Business Use Policy
When establishing guidelines on content published on the firm’s social media platforms, the policy should be written broadly enough to encompass any new forms of social media that arise rather than identifying specific platforms.
A social media policy should be clear on how an employee identifies the firm and should provide full disclosure of his or her role. Employees also need to be clear when they are speaking in an official capacity and when they are not speaking on behalf of the organization.
Consider having procedures that encourage staff to develop and submit content, but only give designated personnel the authority to publish the content. Keep in mind the person authorized to review and post on Twitter might not be the best person to review and publish a blog. Staff charged with publishing social media content will need formal training on style, confidentiality, brand promotion, and appropriate response to comments.
Personal Use Policy
It is more difficult to set guidelines on employees’ personal use of social media, whether that is accessing social media at work or using social media in a personal capacity that links to the firm (such as sending a Facebook “friend” request to a client). Ideally, a social media policy will not be drafted in a vacuum, but rather will be part of a larger set of human resource guidelines. The social media policy can then refer to general expectations, such as those on email usage, bullying, harassment, and confidentiality.
Author D. Neil Berdiev suggests first considering some fundamental questions before drafting a social media policy:1
- Is there a clear distinction between personal and professional social media?
- Are there boundaries to what the firm tries to control when considering what might be seen as personal online space?
- Is “control” even the right word?
There is no universal agreement about how much control a firm should try to exercise over personal social media, but a conversation among those charged with developing the policy can help shape the end result.
There are some common elements among most social media policies. Author Jane Johnston surveyed a variety of organizations and identified common themes.2
The distinction between private and public – Everyone in the firm needs a reminder that private communication can easily find its way into the public space, and individuals are responsible for their communications. The policy should address what the firm considers professional vs. personal communication.
Transparency – A social media policy might address the use of aliases or pseudonyms for nonofficial postings. There might be a requirement that employees be transparent about their relationship to the firm if the post is relevant to the firm’s products or services. Also, consider a reminder that even anonymous posts could be traced back to the individual or firm.
Confidentiality – Although social media policies will vary, it is hard to imagine a policy that did not include a warning about disclosing confidential information.
Noncompliance – What are the implications of noncompliance with clear policies? Also, policies must be applied consistently: a senior manager cannot be allowed to post controversial comments that would result in disciplinary action if made by a lower-level employee.
“Help you” clause – Tone matters. The introduction to the policy should stress that its purpose is to help staff use social media responsibly.
Policies and guidelines will help firms manage their social media presence, but staff buy-in is essential. Staff need to be engaged in at least part of the policy development process and, once developed, they need to understand it. Discussion and feedback are critical. Simply publishing a policy will not ensure compliance. An effective social media policy has to become part of the business culture.
1 D. Neil Berdiev, “Managing Risks of Social Media: The What, Why, and How,” The RMA Journal, 100(8) (May 2018), p. 42.
2 Jane Johnston, “‘Loose Tweets Sink Fleets’ and Other Sage Advice: Social Media Governance, Policies and Guidelines,” Journal of Public Affairs, 15 (Aug. 22 2014), pgs. 175-187.
Mary Jeanne Welsh, CPA (inactive), PhD, is professor emeritus of accounting at La Salle University in Philadelphia and a member of the Pennsylvania CPA Journal Editorial Board. She can be reached at firstname.lastname@example.org.