The fundamental elements of building out your social media policy in financial services.

1. Social Media Policy
Social Media Basics Webinar Series

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 Getting Started on Social is driven by strategy and policy
 Who, What, When, Where and How?
 Your Policy is a Business Plan AND Governance Document
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3. Social Media Policy Best Practices
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Define and Document Your Policy
 Who is authorized?
 Which platforms are
acceptable?
 Include your own governance
and ethics
 Approved technology
 Signed affirmations
 Mitigation
 Ongoing management
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Scott Peterson
Co-Founder
703.722.6688 (office)
571.344.4446 (cell)
www.relaystationmedia.com/ | @sthepeterson
www.linkedin.com/in/scottthepeterson
www.signalboost.com Blog
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5. Social Media Is About
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Sharing
Learning, Engagement, Conversation,
Community
Your policy shouldn‘t be too
restrictive about what is shared!
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6. Elements of Social Media
Policy
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At work:
• Mandatory training to use social media
• Mandatory use of archiving and review system
• Permitted & prohibited platforms
• Right to remove content on company systems
• Right to monitor employees
• Annual policy certification by all employees
• And more
At home:
• Right to monitor any comments about company on Internet
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7. Hub and Spoke Model
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Digital
Marketing
Digital
Events
(webinars)
Social
Platforms
Web
site and
blog
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8. Platforms
Leverage flexibility of multiple
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mediums & formats
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9. The Gateway to Social Media For All
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 Tablets
 Smart Phones
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10. Governance
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 Outline regulations to meet
Identify FINRA
& SEC Rules
that Apply
‒ Retention and Surveillance
‒ Review and Monitoring
‒ Broad Search – rogue accounts, complaints…
Define
Monitoring
Methods
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 Written Supervisory Procedures
 Lexicons and Searches
 Pre-Approving Content

11. Choosing Technology
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Data Aggregation & Retention
• How will you collect data?
Reporting Automation
• How will you supervise content?
Monitoring
• How will you search for what you
“don’t know”?
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12. Rules & Regulations
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FINRA Guidance (1006, 11-39, 12-29)
NASD 2210(b) & 3010
SEC 17a4, 206(4)-7
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13. Social Media Policy Is a
Regulatory Requirement
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SEC Rule 206(4)-7
Firms must adopt and periodically review effectiveness of policies
and procedures regarding social media.
FINRA Reg Notice 10-06
Firms must have a general policy prohibiting any associated
person from engaging in business communications in a social
media site that is not subject to the firm’s supervision… only
those associated persons who have received appropriate training
… may engage in such communications.
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14. Section 7 of
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National Labor Relations
Act
Employees have right to participate in
“concerted activities for the purpose of
collective bargaining or other mutual aid or
protection.”
Prohibiting statements that “damage the
company” is too broad a restriction.
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15. Section 7 of
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National Labor Relations
Act
Be specific!
Include reference that your policy does not
include protected activities
List 19 other categories of behavior can be
prohibited
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16. Social Media Basics Webinar Series
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