Developing a social media strategy


I came across this recently: ‘Social media is not the crux of your argument. It is an enabler. This is your opportunity to lift the conversation from tools to value and to translate the promise and opportunity of social media into an emissary of meaningful engagement that aligns business goals, social media strategies and customer value.’

How do you react to that kind of talk? For me there are a lot of words there and I come across this a lot in my work: volume rather than clarity. The writers of the article are trying to get firms to think not about the media itself but about the message. Why are we communicating rather than how.

The challenge is that social media creates so much noise that firms think we must have a presence and then think about content. As people become more connected and more informed they also become more judgemental; their expectations are increasing and we’re told that they want to engage with businesses rather than just buy their products or services.

Those who have read my previous articles will spot a theme: the starting point to creating your own social media strategy and the T&C implications stemming from it is to ask what does the business want to deliver to customers in order to achieve its own objectives.

Most employers now check social media before deciding on which candidates to invite for interview

It was Will Rogers who said ‘It takes a lifetime to build a good reputation, but you can lose it in a minute.’ So often we see in the news how one ‘small gaff’ ends badly – Prince Philip excepted, given the opportunity would David Cameron choose a different word than swarm? Crew members of an airline were sacked for calling passengers ‘chavs’ on a well known site and a housing manager was demoted for posting that gay marriage would be an equality too far. They might genuinely hold those beliefs but the firms involved were reacting to the damage to their reputation.

Most employers now check social media before deciding on which candidates to invite for interview but how many firms (or schools, colleges and universities) provide guidance on how to think before posting. That picture of you throwing up while wearing a traffic cone was amusing at the time but does it create a favourable impression of you as a professional or the firm that employs you – or is what you or I do in our own time nothing to do with our employer (current or future)?

So how do T&C professionals respond to the challenges presented by an ever increasing range of opportunities to express ourselves and interact with others? If we start with the assumption that every firm wants a good reputation we can ask the question reputation for what? ‘Old money’ might expect a different approach than a celebrity famous only for being famous. Standards of dress and language form part of the culture and these can be part of the induction process – I worked at a firm and it was on my second or third day that it was made clear that short sleeved shirts were not appropriate.

Induction is also an opportunity to set out how the firm expects its staff to use social media. Many of the firms I come across have not thought about having a policy. So we have some ideas that we share with them so that they can develop one. Acknowledging that staff are highly likely to have a presence on social media, the first decision is whether or not your firm is happy for them to state who they work for on their various profiles. Either way an explanation and guidance can be provided:

Either our firm is committed to utilising social media to enhance our profile and reputation and we encourage employees to support our activities through their personal social networking channels.

Or we view social media as a distraction from our business model and require staff not to disclose their employment with the company or make any comment about its activities.

Your induction and your policy should educate staff that the use of social media can pose risks to the firm’s confidential and proprietary information, reputation and can jeopardise compliance with legal obligations. At all times and on all devices staff (permanent and temporary) are to exercise sound judgement and common sense in their use.

Some statements to consider are:

The firm’s official account (venue, name, etc) will be maintained by (name) and any activity by a member of staff requires prior approval from them. As any post may be construed as a financial promotion approval from the compliance officer will (also) be required. A log showing sign off of each item posted will be maintained.

No financial advice is to be provided via personal accounts – any item referring to the firm, its services or the financial services industry generally will require approval from the compliance officer prior to posting. Caution should be exercised when commenting on ‘blogs’: it is for (name) to comment on behalf of the company, your comments should be clearly your personal view.

Also worth thinking about use during office hours e.g. Access to social media for personal use during work time is permitted so long as it does not interfere with your responsibilities or productivity or contain inappropriate material. The company reserves the right to monitor staff activities using our IT resources and communications systems and where inappropriate use is discovered take the necessary action to prevent further abuses of this privilege.

You might also want to build in an addendum on data protection:

We also encourage you to use caution during conversations outside the office as other firms have had the embarrassment and risk to their reputation of staff members talking about clients where they were overheard. All clients have the right to their use of our services being kept confidential unless they agree to provide testimonials which are published.


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Compliance Cubed Financial services is constantly changing - my passion is helping firms function effectively and in compliance with FCA regulation

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