Social Media Policy

THE SOCIAL MEDIA POLICY WORKBOOK

Sharpen your pencils To make this guide work, you will

need to make a few notes!

You like Then why don’t you share

The Social Media Policy Workbook 2

Survey says ...

We ran a survey earlier this year on social media and the law. We asked 183 large brands whether they had a social media policy in place. 19% didn’t have one at all!

You can download the full survey at http://bit.ly/IFSocMedLaw

The rapid growth of social media means that everyone is connected. Not just your marketing department and customers. But your employees, your shareholders, your suppliers and vendors too.

And they do love to talk.

Not everyone associated with your business is aware of the damage they can do to your brand. Bar a few malicious folk, most social media mistakes are innocent: posted by people that are, for the most part, unaware of the risks.

Now is the time to get good social media governance in place. And that starts with a robust policy.

SOCIAL MEDIA IS EvERYWHERE AnD IT’S LEAKY

76

yet 61

of companies consider disclosure of confidential information to be a serious social media legal risk

of companies are not confident that sensitive or confidential information is protected on social media platforms

DOWnLOAD

The Social Media Policy Workbook 3

A SocIAL MedIA poLIcy doeS A whoLe LoT More ThAn juST SeT ouT your ruLeS For SocIAL MedIA engAgeMenT.

It protects your company against liability caused by your workforce

It focuses your attention on the distinction between private and professional social media usage

It makes sure your business complies with the law and regulations

It sets out your expectations, defines standards and identifies responsibilities

It mitigates reputational risk and plugs the gaps in your vulnerabilities

Before and AFTERPolicies are preventative. They help you protect your business before an ugly situation arises.

But you might want to think about afterwards too. Take a look at your insurance, professional indemnity, general liability cover and crisis plans.

not convinced you need a policy

nOT SuRE WHAT A SOCIAL MEDIA POLICY IS

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peek AT whAT hAS hAppened In reAL SITuATIonS And you MIghT ThInk oTherwISe…

HMV might have preferred that those hearing about redundancies didn’t make their feelings quite so well known on Twitter http://bit.ly/V4rtju

Wetherspoons successfully won its case to dismiss an employee because they had a social media policy in place http://bit.ly/160gQfF

Paris Brown steps down as the UK’s first Youth Police and Crime Commissioner six days after being appointed, leaving the Kent Police reputation in tatters http://bit.ly/11nAdAd

A policy can support your case in an employment tribunal http://bit.ly/15v28Se

So what are you waiting for, shall we get started

you hAVe To FInd The TIMe!

The trouble with any policy is that you never appreciate the value of it until something goes wrong. It’s only when you’re in the throes of defence during an employment tribunal, or battling with a tsunami of reputation damaging tweets, that you fully appreciate the brilliance of a well-thought through social media policy.

The Social Media Policy Workbook 5

You might like to print the rest of this workbook out

So you can scribble down your thoughts. By the end you will have a framework for your policy – Whoop! Job done.

your policy is business critical

You need to look at the BIg pIcTure first to determine the business impact and plug all the vulnerabilities

Take it from the top

Lots and lots of checklistsActually it’s mostly lots of questions. Questions that will help you create a social media policy to be proud of!

The Social Media Policy Workbook 6

consider all your potential stakeholders

Employees

Ex employees

IT / Tech

Legal

Marketing

Unions

Tele / Home workers

Casual & temporary staff

Volunteers

Suppliers

Vendors / Partners

Shareholders

Other?

get buy-in

If your policy is going to succeed then you need buy-in from the top and across critical departments. Think about who you might want on a policy team and who might champion your efforts

Gather the detail Before putting pen to paper you need to hoover up all the relevant policies and documents from across your business.

What broad issues do you want to address with your policy?

Who is your policy for?

How are you already active in social media?

A POLICY WITH PuRPOSEyour poLIcy needS To STrIke The rIghT BALAnce BeTween SeTTIng ouT The ruLeS; educATIng And deFInIng BoundArIeS; And coMMunIcATIng SIMpLy.

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your SocIAL MedIA poLIcy wILL need To FIT wITh your currenT prAcTIceS.

Identify existing documents that will integrate and impact your social media policy, including:

Existing crisis documentation

Compliance and regulatory documents

Advertising or promotional guidelines

Current company policies

Grievance, harassment and disciplinary procedures

Standard employment contracts

Business continuity plans

Prevalent restrictive covenants

Employee Handbook

Platform terms of use

IT & electronic communications (email) policy

Privacy and data protection policy

Recruitment policy

Sensitive information and security policies

Copyright and IP policy

Current policies might include these

Think stylishlyWhilst you review all your documents, you can also note down the tone, format and design style – to keep your social policy in line with your corporate identity.

Maybe a revision or two You might actually want to also amend some of your current policies whilst you are revisiting practices. Make them current for the social media age

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uncoVer The InSIghTS ThAT TAILor your poLIcy To your coMpAny. There Are Two we recoMMend…

1. A vulnerability audit

In our humble opinionEarly consultation with your co-workers and stakeholders will bring you greater buy-in later down the line when you are ready to publish your policy. This bit does take time, but it is phenomenal for raising awareness.

ASK AnD YOu SHALL

2. Skills and capabilities

How in depth will you need to explain terms and social platforms in your policy? Well, it depends on the skills and capabilities of your workforce. Think about the questions you might ask in the following categories …

conduct interview

Talking to executives across the disciplines helps you unearth the potential issues.

Ask the right questions and you may find potential vulnerabilities your senior team may not even be aware of

Identify loose cannons

Examine the weaknesses in company communications and operations. Consider what might happen if you lose the internet or get hacked

Imagine scenarios

Brainstorm the differing issues and anticipate the outcomes. Plan for each situation

Social media knowledge Involvement in social media for the company

usage of social media platforms Tools used for social communication

Always conduct your interviews in confidence

Brainstorming across disciplines makes certain

that you consider all the risks

Helps you identify and

plug the gaps

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Enough assimilating information, let ’s get on with drafting the darn thing

now for the social media

click here

and check out

30 other UK

company social

media policies

Of course you must follow the policy model of your organisation, but the following guidelines will help you consider all the elements

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MAke A STATeMenT

poSITIon And deFIne

what is the purpose of your social media policy?

(Tell those reading what this will help them do; how it applies to them; and how it fits with the company brand, ethos and culture)

Tell them which other company policies this supplements

who does this apply to? (Which personnel and which departments?)

You might need a separate policy for those that communicate on behalf of the company through social media – something more in-depth and platform specific.

POLICY TEMPLATE

Kick start your policy by defining

your terms, the level of guidance and

how it applies to your other policies

Set your scene and

manage expectations

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WHICH MEDIA MATTERSocIAL MedIA IS ALwAyS eVoLVIng So your deFInITIonS ShouLd IncLude The MAjor pLATForMS, And ALSo FuTure prooF For neTworkS yeT To LAunch

platforms to consider and add to:

Facebook

Twitter

Blogs

Pinterest

Instagram

Wikipedia

YouTube

Forums

Community sites

MySpace

Tumblr

Google+

LinkedIn

Social bookmarking sites (Diigo, StumbleUpon)

Ning

Flickr

Other

Don’t be tempted to write detailed clauses to cover every single platform or eventuality – it will make your policy too long to be intelligible

!*#!

*!

Create a definitive list of approved social media platforms for company engagement

Get a bit

explicit

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You might also want to consider a tool that allows you to store all your posts and tweets, securely. We use Social Safehttp://bit.ly/savesocial

Securing your network Who has permission to set up a company profile and where will passwords be stored? How can employees gain permission to access or set up company social profiles?

Authorised tools to use for work communications

• Monitoring tools

• Social media engagement / customer service tools

• Measurement and analytics tools linked to profiles

responsibilities

• Who has overall responsibility for this policy?

• Who will monitor, review and escalate issues if need be?

• Which employees have permission to engage in social media on behalf of the company?

SOCIAL SECuRITY

A SAFe STArT. FroM The TooLS you uSe, To The pASSwordS you SeT, ouTLIne whAT cAn And cAnnoT Be uSed – And who TAkeS reSponSIBILITy

The Social Media Policy Workbook 13

A good policy starts from a position of trust - your people want to do the right thing, so you need to create a safe framework of practical information

Identify elements for a code of conduct

you might want to include:

What is acceptable behaviour – honesty and responsibility?

Fair use during working hours

What’s appropriate when sharing information internally and protecting personal reputations?

The guidelines for external use – representing the company views and protecting the company reputation

Confidentiality, copyright and IP and gaining authorisation

Competitions, promotions and endorsements

Acceptable use of third party content and links

Knowledge of social platform terms of use

Consideration of colleagues and privacy - avoiding gossip or heated debates

Some general tips and advice for being safe in social media

SPELL IT OuTouTLIne AccepTABLe BehAVIour: cLeAr And uneQuIVocAL guIdeLIneS work, BuT So doeS LeTTIng your eMpLoyeeS TAke reSponSIBILITy. eMpower your STAFF, And you’LL geT BeTTer reSuLTS

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Draw a line between work and home life–but make clear when work cannot leak into private lives / or in many cases today, personal usage on a mobile device

For some staff, you may need to show examples of defamation, libel or copyright infringement in social media

Try and keep the rules minimal and positive - more do than don’T!

Are there current policies they must still adhere to outside of working hours, such as bullying, harassment and data protection?

which elements will you tailor to your audience with clear explanations?

what is your expectation of personal social media activity?

MAKE IT YOuRS AnD THEIRS TOOTAILor To you And your STAFF: MAke IT perSonAL And IncLude exAMpLeS. IT heLpS To MAke eVeryThIng crySTAL cLeAr And reLeVAnT

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what do you consider social media misconduct

or misuse?

what do you consider to be confidential

information?

what regulatory and legal compliances

must be adhered to?

Make clear the company position on abusive, obscene, discriminatory, harassing, derogatory or defamatory content

want to swot up on social media law?

Have a look at our ‘social media and the law’ best practice paper. Written in plain English and designed for those not legally minded, it highlights the laws you should be aware of and the steps you can take to prevent litigation. http://bit.ly/LegalSocial

get the lawyers in!Sure it can be expensive. But then litigation can be more expensive

Detail what is sensitive, anti-competitive, private or confidential

YOu nEED TO SET SOME RuLESA code oF conducT And TAILored guIdeLIneS SeT The FrAMework. BuT you wILL STILL need To hAVe SoMe cLeAr ruLeS. hArd STopS ThAT uneQuIVocALLy TeLL reAderS whAT you expecT.

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what to do if someone makes a mistake on a social network, who should be told and how might it be redressed?

disclaimers to use on personal social networks

how will you help stakeholders keep safe? List some of the areas worth explaining such as:

how to raise a grievance if you have been harassed, bullied or offended by material posted by a colleague on social media

WHAT TO DO IF ThIngS geT ugLy or dIFFIcuLT, whAT do you wAnT your STAkehoLderS To do? conSIder how BeST To ShAre dIFFIcuLT SITuATIonS And how perSonneL cAn TAke preVenTATIVe STepS

• How to set privacy settings on networks (and when is private not really private!)

• Where to find ‘terms of use’ for the popular platforms. How to be safe online.

• How will you escalate an issue if it gets out of hand?

• Pre-prepared statements might make it easier for some of your employees who are active on social networks

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Watch out as the laws on permissible employee monitoring vary between country and in the USA, between States

Employers can be held vicariously liable for the actions of employees on social networking sites.

There is a useful explanation on http://bit.ly/14a3d0i

what and how the company may monitor employees?Ensuring you adhere to the law and are not excessively nosey!

what is your disciplinary procedure? Will your steps to disciplinary action differ from your normal policy?

explain potential staff legal liability You may need to spell out where there are legal consequences to the individual.

ACTIOn AnD COnSEquEnCESuLTIMATeLy, BreAch oF ruLeS cAn hAVe wIder conSeQuenceS For BoTh The IndIVIduAL And The coMpAny. you need To InForM STAkehoLderS oF The AcTIon you wILL TAke.

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Advice from people who are immersed in social media every single day.

immediate future has helped a number of well-known brands create robust and valuable social media policies.

Let’s be straight, we are not lawyers. But using our hands-on experience in social, we work with companies to deliver pragmatic advice on what needs to be included in a social media policy. We can quickly identify your social vulnerabilities and the practical solutions that will still keep you talking to your customers!

OMG THERE IS A LOT TO DOdeVeLopIng A rounded And FuLLy IncLuSIVe poLIcy cAn SeeM preTTy dAunTIng. IT cerTAInLy TAkeS TIMe And cAn InVoLVe A nuMBer oF key dIScIpLIneS

The immediate future framework

Drawing on best practice across multiple functions, disciplines and industry sectors, IF considers:

• Nuances gleaned from using social media daily (including the challenges of working with media not always designed for enterprise)

• Use of integrated multichannel social media and cross functional requirements

• Capabilities of staff and policy guidance that makes clear expectations

• Fit with the brand – tone of voice, image uses, etc.

• Uncover and address vulnerabilities and reputation risk to the brand

• Ensuring clauses fit with social networks’ Terms of Use

• Using plain language definitions to make the document understandable to all employees

• Highlight which laws need to be considered and where you should involve legal teams, HR and regulatory bodies

• Potential crisis scenarios, including what to do if your profile is hacked

• Technology considerations from NFC to platform changes

• Potential conflicts or inconsistencies that might arise in the future

• Future management of social media information and storage of data for disclosure

• Awareness of upcoming legislation such as changes to EU identity and privacy laws

A review to plug the gaps

You might already have a policy in place, but

are now considering a review. IF will help you

update and future-proof your guidance.

Create a policy from scratch

Guiding your company through the development

of a policy, the IF team will work closely with all

your stakeholders.

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Expect your draft to be an iterative

process involving people across the

company to refine and develop it further

But that isn’t the end of it. There is a lot more to do to communicate your policy and ensure that it will stand up in a tribunal too

now you can start drafting your own policy

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Once the policy is on the page you need to get it off the page! And quickly. Your employees and stakeholders need to understand your policy. But more importantly you need to show that you have trained and communicated if you are to avoid litigation.

what steps will you take to train employees?

Who do you need to train? How often will you train?Will the course be on or offline or a combination of both?

what essential elements will the training courses include?

Don’t forget to include some real life examples

Thinking about outsourcing your training? Then give Katy a call on 0845 408 2031

She trains for the IDM, CiPR and CIM too.

Consider whether to tailor the training to differing audiences and their responsibilities within the organisation

nExT STOP IS COMMunICATIOn AnD TRAInInG

When Apple faced a tribunal hearing it was able to win its case because it could show that it had trained its staff and communicated the policy http://bit.ly/Zhyc8i

66of employees are not very aware of social platform terms of use

The Social Media Policy Workbook 21

Need help to devise creative communications from video through to desktop reminders? Then give the IF team a shout – we are quite good at this stuff

which elements of the policy will you bring to life with internal communications campaigns?

what on-going programmes will drip feed information and encourage feedback and questions?

how will you future proof your policy and adopt policies arising from employee and stakeholder feedback?

KEEP On COMMunICATInG

Beyond TrAInIng And MAkIng Sure your TeAMS Are ALL deLIVerIng BeST prAcTIce SocIAL MedIA, you need To keep SocIAL MedIA FronT oF MInd. geT TogeTher wITh InTernAL coMMS, ThInk cAMpAIgnS And STArT A progrAMMe To keep your poLIcy FronT oF MInd

only 6are very aware of the cap code

and ASA regulations on

advertising and promotion

Do consider how you will future proof. Who needs to be part of an on-going policy team and how often should you meet and review?

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There is a lot to consider when creating a crisis plan …

What constitutes a crisis?

What scenarios are likely (gleaned from your vulnerability audit)?

What will be your escalation process?

Who will take responsibility, and who needs to be involved?

How will you monitor and manage a crisis?

How will you communicate with those not at the coalface of a crisis?

More?

More?

ThIngS go wrong. eVen wITh A BeLT And BrAceS poLIcy, you cAnnoT LegISLATe For eVery dAMAgIng eVenTuALITy. creATe A crISIS pLAn. A SocIAL MedIA crISIS pLAn

Adam Lewis, MD and crisis expert at IF, suggests that developing your crisis plans alongside your policy ensures you plug all the vulnerability gaps.

BE SMART AnD COnSIDER CRISIS

Yes, there is a lot more to a crisis plan. We could create another 20 pages. But now you have got this far, why don’t you talk to us at immediate future – we can do it for you.

And once the plan is in place, we can help you run a crisis simulation, which puts your team under the same crisis pressures as real life, but in a secure and safe environment where you can all learn.

We even use a clever social media simulation tool that lets participants tweet, blog, write news stories and behave just as they would in social media. But behind your firewall – safe and protected

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A HELICOPTER vIEW

In our experience creating a policy is actually incredibly rewarding.

You get to talk to people across your organisation. You get to develop something for a new communications age. And you get to enhance your own knowledge.

enjoy it!

We do!

Set goals and define audiences

1

9

8

25

6

7

3

4

Now go develop your crisis plan

Train and communicate

Vulnerability audit and survey staff capabilities

Make clear the purpose and define the media

Explain how to take action and

the consequences of misuse

Make clear the purpose and define the media

Outline responsibilities, tools and authorities

Gather information

your SocIAL MedIA poLIcy

The Social Media Policy Workbook 24

Why don’t we connect? We would be delighted to meet you, or you can call us on

0845 408 2031

You can also chat to us anytime:

IF on Twitter (@iftweeter)

IF on google+

IF on LinkedIn

katy howell on Twitter (@katyhowell)

katy howell on LinkedIn Oh! And if you like this workbook, please share on social, comment on our blog or just tell everyone you know!

WAnTInG MOREIf you like the workbook then you might want to download (for free)….

Risky Business: How to stay legal when using social media

With social media litigation increasing, now is the time to get better informed. Download the immediate future social media law guide to discover:

What laws and regulations are relevant to social media

Guidelines to help you protect confidential information

The steps you can take to ensure your competitions and promotions comply with ASA regulations and gaming laws

How you might protect ownership of your social media profiles?

What content you can share and curate without breaking copyright or IP?

How social activity impacts employment law?

Shall we be social