Wednesday, August 15 - In this first part of a series exploring the vast and timely topic, guests Alex Ross and Jacob Chang focus on social media policies in the workplace. They shared all the tips and resources you need to craft a suitable policy and educate your staff about their rights.
The WOMMA Guide to Disclosure in Social Media Marketing is a great resource to check out. Please visit http://womma.org/ethics/privacy_guidance, to download your own Social Media Marketing Disclosure Guide.
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5. Presenters
Michael DeLong Jacob Chang Alexandra Ross
TechSoup TechSoup Paragon Legal
Facilitator Presenter Presenter
Assisting with chat: Ale Bezdikian
9. Tips for Personal Use of Social Media
• Read the Privacy Policy before you join sites or download apps
• Review Privacy Settings
– Facebook (set to friends, limit sharing of info re apps, block ads)
– Twitter – can set to private instead of public tweets
• Review Permission Screens for Facebook apps (optional vs.
required)
• Use common sense (posts live forever)
• Employment context
– what to do if potential employer asks for your Facebook password
– now illegal in some states (Illinois and Maryland, pending in California)
10. Social Media Policy
• HR policy governing use of Social Media by employees
• Online database of social media policies
http://socialmediagovernance.com/policies.php
• Tie into other company policies regarding email, use of
internet, confidentiality etc.
• Topics to cover
- policy applies to multi-media, social networking websites, blogs
and wikis for both professional and personal use
- whether or not use at work / on company equipment is permitted
-postings should not disclose any information that is confidential or
proprietary
- if an employee comments on any aspect of the company's business
11. Social Media Policy
-the disclaimer should be something like "the views expressed are
mine alone and do not necessarily reflect the views of (your companies
name)”
-employees should neither claim nor imply that they are speaking on
the company's behalf
-internet postings should not include company logos or trademarks
unless permission is asked for and granted
-internet postings must respect
copyright, trademark, defamation, fair use, financial disclosure, and other
applicable laws
-no posts containing PII - information that allows a page visitor to
determine a poster’s identity or third party’s identity and that includes off-
site contact information (e.g. name plus email, phone number, physical
address or other contact information; SS #, driver’s license number, credit
card number)
-PR issues – reminder that employees should not speak to the media
on company’s behalf
12. Social Media Policy
National Labor Relations Board (NLRB) issues can be tricky
• how to craft workplace social media policies that are consistent with
the terms of the National Labor Relations Act (NLRA).
• Section 7 of the NLRA provides employees with the right to engage in
“concerted activities for the purpose of collective bargaining or
other mutual aid or protection.”
• Social Media policies that discourage the exercise of these rights may
run afoul of the NLRA.
• NLRB questions use of common social media policy provisions
• Precise wording of the policy is critical to whether it is considered
overbroad by the NLRB
• Social media policies that distinguish between the prohibited behavior
and concerted activities excluded by the policy, and that provide
examples of each, would be more likely to withstand NLRB
scrutiny
• Legal review recommended
13. Special Rules for certain Social Media
• All content posted must comply with all company policies as noted
above, in addition to the Terms of Use and Privacy Policy of each
Social Media site.
• Twitter
-Account Name. If tweeting on behalf of the company, name
should reflect that (e.g. @AvonAmy). Post list on company website of
employees tweeting on behalf of the company.
-Company Assets. It should be clear that the twitter account is a
company asset. If the associate tweeting on behalf of the company
should leave, they will need to leave their account behind as well.
-Email Address. Company twitter accounts should be used with a
company email address (@avon.com) Business email addresses should
not be used for personal social media accounts.
-may wish to require employees to “verify” their Twitter
accounts
14. Special Rules for certain Social Media
• Facebook
-Before allowing employee use of Facebook for business, implement
process to coordinate with Social Media team
-Official company site vs. personal pages of employees (personal
profiles or groups should not be used for commercial purposes)
• Pinterest
-Since images on Pinterest aren’t usually created by the pinner, there
are copyright considerations. Pinterest does not ask users to consider
permissions before each "pin," aiming to make the user experience seamless.
-employees that pin content should confirm they own all rights to
the images and that repinning would be an accepted use
15. Special Rules for certain Social Media
• YouTube
-copyright concerns re posting or using third
party video content without permission.]
- for consistency and authentication
encourage use of the "network" template where
employee channels can link to official corporate
channels
17. Social Media Review- Framework and
Approach
Sample components of social media activity and key business objectives as it relates to strategy, operations, reporting, compliance and information technology maturity.
Planning & Metrics & Information
Strategy Compliance
Operations Reporting Technology
The Social Media Ensure integrity
Strategy is aligned Processes and Relevant metrics, and The organizations
associated financial/ actions related to and security of
with the overall procedures have corporate
corporate goals and been implemented operational reports social media comply
have been with all applicable information
objectives and has a to ensure the systems in order to
supporting successful execution established to ensure federal and local
successful regulatory issues; as maintain a positive
governance of the social media brand through the
structure and plan plan implementation and well as internal
use of social media policies use of social media
of execution
18. Social Media 5
Maturity Model 4
Transformational
• The organization
Functional has moved into a
3 collaborative
network that
• SM is applied for a
Experimental creates new value
specific purpose
through the use of
• SM is executed
SM.
2 • Departments set up
where activities can
• SM application
be a value-add
independent development
Ad Hoc initiatives
initiatives, work in • ‘Crowdsourcing’ is
• Key dept’s, are
silos leveraged
1 • Developing needs
active on a SM
• SM is fully
• Individual platform
for SM strategy and integrated into the
Pre-Social employees/teams • Formal SM policy
policy strategy and
use social media on • Defined procedures
• No structure for processes, enabling
their own for moderating
answering and the organization to
• Have not yet tried • No social media conversations
responding take the lead in
to do anything in strategy or policy • Clear and
• Have not put in the exploiting
the Social Web. • Team is meaningful
investment to really opportunities
• Don’t have a page communicating on conversations with
start meaningful • Social media
on Facebook or any social platform but customers
conversations with influencers are
other Social customers can not • SM is utilized for
their customers. leveraged to
network. interact with value add activities
• Team is improve reach and
• No current plan or company such as public
communicating on engagement
strategy to engage • Customers can not relations or
social platform but
with social media in interact with each customer service
not fully engaged
the near future other and research .
with customers
• Collaboration
among
departments
Tactical Strategic
19. Social Media Planning
Goals – identify the goals that are unique to the applications and the department
or market
• Channels – identify the channels that will be used
• Engagement – include specifics on the level of engagement. For example, will
social media be used to listen, share information, comment on other content, or
create original content such as blog post or podcast.
• Staffing and Funding – define resource requirements in order to support the
social media plan
• Metrics – identify the relevant metrics that support the goals
• Social Media Policies – define the rules of engagement for social media use
• Training curriculum for associates
20. Social Media Monitoring
• Determine the best opportunities to impact business objectives such as identifying
areas of risk or unique issues (e.g customer service, PR)
• Identify what you need to know to make an impact on the business objectives. (e.g.if
the objective is to build a pipeline of professional level associates, determine who
are the current thought leaders are in the industry, who is engaged in the
conversation and how their thoughts are relevant to the type of people you are
seeking)
• Identify who will be in the conversation
• Determine where the most meaningful conversations are most likely to occur
• Understand who in the organization is in the best position to gain actionable
• insights from the listening activities
• Determine which tools will be best able to help you listen and collect the right
information.
21. Social Media Monitoring and Control Tools
Internal – teams or social media managers that are trained to review and pull
content based on certain guidelines and escalation paths. In some
cases, legal, HR, PR may need to review and approve before content is
pulled.
Efficiencies can be gained by determining how tools that monitor and control
social media (eg Radian6) fit into broader information governance.
-Radian6 gathers the discussions happening online and gives businesses the
ability to analyze, manage, track, and report on their social media monitoring
and engagement efforts. Radian6 provides the social media monitoring
platform for marketing, communications and customer support
professionals.
22. eDiscovery and Retention Requirements
Although there are some specific laws and regulations, such as the SEC Rule 17a-4, that
apply to certain verticals that make the governance of social media relatively easy, for
most other businesses, there are no clear rules.
When it comes to retention many companies keep data as the default option, because
it is easy.
Retaining masses of social media content will lead to the same issues as e-mail has: big
storage bills, difficulties in information retrieval and legal headaches.
Make rational retention decisions, based first on applicable laws and regulations where
they exist and then common sense business needs.
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Editor's Notes
This slide shows a global look at the social media environment,
The U.S. Country snapshot) was obtained from comScore’s 2011 survey “Top 10 Need-to-Knows About Social Networking and Where It’s Headed” to show relevant social media statistics for the US Survey is based on Internet usage from home and work based computers from opt-in research panel, consisting of 2 Million people sourced from 171 countries. See the following link for further details: http://www.comscore.com/Press_Events/Presentations_Whitepapers/2011/it_is_a_social_world_top_10_need-to-knows_about_social_networkingOnline Population Visiting Social Networks- 185.2 (total social networking audience)/188.5 (total audience)= .98 (98%)Share of Time Spent on Social Networking- Time spent on Social Networking as a percentage of total time onlineSocial Networking Demographic Reach- Social Networking reached at least 95.3 percent of online users who are male, age 55 and older; etc. Average Engagement with Social Networking- Average hours in a month per visitor by age group%Reach= The estimated number of individuals in the audience of a broadcast that is reached at least once during a specific period of time. 156.0 (unique visitors)/188.5 (total audience)=.828 (82.8% Reach)
A social media policy with strong cross-functional input can reduce compliance, litigation and security risks. At a minimum, the policy should cover what the organization will and will not do online, what employees can and cannot do, and what the public can and cannot do on company social media sites. It is also recommended to have a well-communicated social media policy in place before leveraging social media for business use.
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Prohibitions on the disclosureof confidential or “non-public” information, or of matters concerning individual privacy rights, via social media. Instructions not to reveal non-public information may be unenforceable as applied to discussions about, or criticismof, the employer’s labor policiesand its treatment of employees.The NLRB noted such a tension in policy requiring social media usersnot to “reveal non-public company information on any public site,” where the explanation of non-public company information did not include appropriate carve-outs for activities protected under Section 7. • Prohibitions on the disclosureof an individual’s personal information via social media. The NLRB took issue with a social media policy instructing employees: “[D] on’t disclose [personal information regarding employees and other third parties] in any way via social media or other online activities.” As the NLRB explained, “[I]n the absence of clarification, employees would reasonably construe it to include information about employee wages and their working conditions.” • Discouragements of the “friending” of one’s co-workers. Accordingto the third memorandum, a policy statement advising employees to “think carefully about ‘friending’ other co-workers” could be construed as unlawfully discouraging employees from communicating regarding the terms of their employment. • Requirements that employee grievances be addressed through internal procedures, rather than aired online. A social media policy providing the employer “believes that individuals are more likely to resolve concerns about work by speaking directly with co-workers, supervisors or other management-level personnel than by posting complaints on the Internet” was found to be unlawful, according to the NLRB, because it might inhibit employees from “seeking redress through alternative forums.” The NLRB noted, however, that employers may “reasonably suggest” availing of internal dispute resolution procedures. • Prohibitions on the sending of unsolicited communications to other employees. The NLRB found a policy requiring employees to report receiving “unsolicited or inappropriate electronic communications” to be an impermissible restraint on employees’ right to discuss their employment conditions. • Restrictions on public discussions of personal opinions regarding work. One policy discussed in the memorandum expressly permitted employees to discuss online their personal opinions about work-related issues, but only to other employees and not to the general public. The NLRB found this overbroad because the right to discuss employment conditions extends to discussions with non-employees. • Prohibitions on comments regarding pending legal matters. A policy providing, “Don’t comment on any legal matters, including pending litigation or disputes,” was found to be unlawful on the basis that it “restricts employees from discussing the protected subject of potential claims” against their employer. Prohibitions on responding to government inquiries. The NLRB found that one employer’s directionto employees not to respond to communications from government agencies was overbroad “to the extent that it restricts employees from their protected right to converse with [NLRB] agents or otherwise concertedly seek the help of government agencies regarding working conditions, or respond to inquiries from government agencies regarding the same.” Requirements that employees check with the legal department or human resources (HR) department prior to posting or communicating with the media. Requiring employees to secure permission from their employer before engaging in activities protected under Section 7, the memorandum noted, is prohibited by the NLRA.
In yourSocial Media policy, you may wish to go into detail about what is permissible on certain social media sites.
Can you move this slide 4 and 5 to just before the one that starts the social media to promote your business series?
Definition: Crowdsourcing- a distributed problem-solving and production process that involves outsourcing tasks to a network of people, also known as the crowd. This process can occur both online and offline. The difference between crowdsourcing and ordinary outsourcing is that a task or problem is outsourced to an undefined public rather than a specific other body.
Consider including the following in the social media plan:
Can you add bullets here to be consistent with other slides?
Can you add bullets here to be consistent with other slides?