Archive for category Employee Behavior
What’s the Buzz? Tell Me What’s Happening
Posted by Kailash_Ambwani in Actiance, Collaboration, Compliance, Electronically Stored Information (ESI), Employee Behavior, Enterprise 2.0, Financial Services, personal v professional, Trends on April 18, 2013
The buzz in the enterprise is Big Data. Pick up any publication covering technology or business these days and you will see articles about the proliferation of Big Data; how it happens and how it will impact our lives. Certainly, there is a ton of data flooding in, offering tremendous opportunity to predict new trends that can drive our business in exciting ways. But there are two important steps in the harnessing of Big Data to achieve its potential. First you have capture and store the data; second you need to analyze the data. Once you have visibility you can ‘listen’ to trends generated by your customers and marketplace.
But, while most companies are listening to what customers are saying, they’re often not listening to what their employees are saying.
The old adage “the CEO is the last to know” no longer has to hold true. Big Data can help you learn about your employees’ experiences as much as the customer experience. If we can leverage Big Data to create an experience for the customer that exceeds their expectations and results in higher satisfaction, can we not use Big Data to achieve the same with our employees?
With Big Data we can change how we engage our employees. We can understand the trending themes, the sentiment, who the key “connectors” and subject matter experts are, and even the high risk areas. We can safely project that this will result in:
- Higher job satisfaction
- A more engaged, enthusiastic workforce
- Longer employee retention
- Better productivity
Not unlike the customer experience we can create with insights from Big Data, we can create a better employee experience that results in a positive, transparent and more productive work environment. All of which gives us a competitive edge.
Isn’t that really the potential of Big Data for the enterprise?
Lessons We Can Learn from the Youth PCC Twitter Meltdown in the UK
Posted by doates in Actiance, Employee Behavior, Twitter on April 11, 2013
In this week’s UK news, we’ve seen some outrageous Twitter revelations and the subsequent resignation of the Kent Youth Police and Crime Commissioner, Paris Brown. The scenario raises a number of issues regarding how employers vet new staff, not only based on traditional CVs and references, but also considering their social media profiles.
The reality is that when a member of staff becomes exposed in the light of historic tweets or other online activities in public networks, it does cast a shadow on the individual – but ultimately it is the employer that is at fault for failing to properly assess and support the candidate.
There are three fundamental methods of ensuring your organisation does not suffer a painful media disclosure such as the one recently experienced by the Police Service.
1. Introduce social media review policies
Ensure that you have internal HR processes and tools for identifying and vetting new candidates across social media networks. A candidate may have a number of different public profiles using a variation of social media channels – all of which will help paint a complementary image of the personality, attitudes and moral standpoints of the person. As part of your employment strategy, the organisation should have a set of clear definitions in place which outline behaviour or attitudes which are not acceptable; be they online or offline. We have published two papers that will help you create the right policies: The Legal Issues of Social Media, UK edition and The Six Essential Principles for Social Media Success.
2. Have a contingency plan
When faced with inconsistencies or questionable public online activities, you may still decide to proceed with the employment based on the core skills and experience of the candidate. However, any uncovered issues need to be openly discussed as part of the employment process. There should be a clear understanding of how the employee is expected to behave as a representative of the business and you should make decisions on whether any unsuitable tweets, blogs or profiles should be deleted. By critically reviewing content you can pre-empt a media backlash at a later stage.
3. Enable future compliance
Guidelines for online behaviour are no longer an agenda item just for public service institutions. All organisations need to be aware of the risks of employees being active on public online networks, but also embrace the power of the “social employee”. Today more than ever, we have access to the communication platforms and knowledge to truly influence the world around us. Just as the decision behind recruiting the youth PCC was very much based on her ability to represent and speak to her peers, businesses must recognise that employees can impact the business environment through their presence within their social media circles – so they should be encouraged and supported to do so in a compliant fashion.
Ultimately, whilst anyone’s behaviour on social platforms is their own responsibility, it is beholden to the organisation to warrant that the author is educated, supported and managed to ensure that the reputational risk is minimised. As the Romans would have said – Caveo Utor (Employer beware!)
Engaging the Remote Worker: Innovation vs. Productivity
Posted by Kailash_Ambwani in Employee Behavior on March 11, 2013
The recent ban on remote working at Yahoo! is counter-productive to being successful in today’s connected-enterprise. Certainly their situation, as reported by the media, is different than most; a large remote workforce who is not productive, some of whom allegedly collect pay while working on outside projects. Marissa Mayer undoubtedly inherited this situation and the blame falls squarely on the backs of managers who have rewarded poor performance, whether in the office or at home. However, with the walls between work and home collapsing, the ability to leverage talent on a global basis and the knowledge worker’s expectation to be able to work anywhere, anytime it behooves us to embrace remote workers.
There is no denying the value of ‘water cooler’ discussions and face time with colleagues. Innovation trades on the serendipitous exchange of information. We have yet to find a substitute for bumping into a colleague in the hallway and discovering a new way of thinking about a project, or finding a unique way to look at a complex problem over a sandwich. At Actiance we put a premium on this type of engagement and often fly executives from around the globe to headquarters to create these opportunities. Conversely, productivity, which trades on process, is often best served by an environment that minimizes distractions. Who hasn’t welcomed flying at 30,000 feet just to be able to power through a backlog of emails, read documents or finalize a project summary uninterrupted? The bottom line is you need both: innovation and productivity.
Whether you have workers who use a home office or distributed teams across global offices you need to find a balance between innovation and productivity. One of the ways we engage our distributed workforce, and hopefully find the balance, is with technology. Video is used at staff meetings, weekly summaries are captured and shared on Connections, and our team engages on social networks via our Socialite product. Innovation with productivity is achieved through engagement made possible by technology, and wise management.
Here are some tips we’ve gained over the years to help you successfully engage with and manage your remote workforce. You’ll note they are not all that different than what a good manager does with non-remote workers in the office.
- Consistent: Hold regular conversations with your remote workers, either via chat, social networks or email.
- Engage: Don’t just talk about the projects you are working on. Find out what matters to the remote workers, discuss relevant industry news, what’s happening in HQ…make them feel like you are interested in them and they are part of the team.
- Expectations: Set and reinforce expectations via consistent engagement and dialogue.
- Policy: Make sure your remote work policy is well crafted and communicated across the work force. It needs to be fair for all.
- Reward: Let them, and others, know when they have been successful. Just because you can’t see them, doesn’t mean sharing their triumphs with others isn’t important to them.
- Support: Discover, define and help them with the challenges that they face in performing their tasks regardless if they are working remotely or not. Just because they are out of the sight, doesn’t mean they don’t face challenges.
- Technology: Use it wisely. Perhaps you have team discussions on a collaboration platform, but more personal 1:1 discussions with individual team members on a different channel, such as video. So he/she knows they can contribute openly on the team collaboration platform and have deeper discussions on another.
There are many different ways to embrace a remote workforce and make it successful. We’d like to hear yours. Feel free to leave a comment below.
Belbey Blogs: Are you Ready for Your Social Media Crisis? Consider War Games.
Posted by belbey in Actiance, Employee Behavior, Financial Services on February 25, 2013
Todays’ post is from Joanna Belbey, Social Media and Compliance Specialist, Actiance. @Belbey
We all know that the continued success of any business depends on its reputation. That’s the primary purpose of all our advertising, marketing and public relations campaigns. But what happens when something goes wrong? All that hard work can vanish with one poorly handled crisis.
That’s why most larger firms have Crisis Communications Plans that describe the processes to follow for a number of scenarios. Some of the smarter firms have even created plans just for social media. They recognize that at some point, you can pretty much guarantee that your firm will attract some very public, very unwelcome negative attention. And that social media will just amplify it. In fact, as firms are discovering, social media can actually create the crisis.
Once the plans are approved, most firms cross their fingers and secretly hope that it never happens to them.
However, at a recent Business Development Institute event, I discovered that a few firms actually test their preparedness by conducting “war games”. I was curious how that would work, so after the event, I spoke with the media relations and social media team at a large financial services firm to learn how they did it.
They relayed that when their sales teams began to use social media, they became acutely aware of both the benefit and risk for the organization. So they enlisted their Public Relations Firm of Record to help them test both their traditional and social media crisis communications plans in real time.
Goals:
- Respond appropriately to a crisis in real time, which would involve identifying an issue, making the decision to respond, crafting the response in the right tone, gaining approval of the response, and delivering the response publically across numerous outlets in a timely manner.
- Proactively communicate with various audiences that include: customers, employees, agents, news media, local community, company management, directors and investors, trade associations, government elected officials, regulators and other authorities and suppliers.
- Find the right balance between thoughtfulness and urgency.
Approach:
- Consciously create anxiety to make the test as real and memorable as possible.
- Pick topic in advance.
- Simulation to be cross functional: identify and gather all key stakeholders such as legal, risk, compliance, public relations, marketing, customer service, corporate communications, investor relations, human relations, subject matter experts, senior execs, IT and Security.
- Inform senior management in advance.
- Guarantee no leaks. Create a safe, secure environment by conducting the test off site in controlled environment. In this case, no email was used, all communications among the team were paper-based. Personal electronics were not allowed in the war room during event.
- Test the plans over time. Every 1.5 hours represented a day, as an acute crisis can extend over several days.
- Monitor activities across traditional and social media.
- Respond in real time across multiple outlets to the crisis.
Lessons learned:
- Social media both creates traditional media and adds a level of urgency / responsiveness. Responding to thousands (or hundreds of thousands) of comments across social media is very different that handling incoming phone calls from traditional media.
- Having access to pre-identified subject matter experts with well defined approval processes, allows the ability to craft realistic responses quickly.
- Combining two crisis communications plans (traditional and social media) insures accountability.
And as planned, the test was stressful and memorable. “We’re glad it’s over!” said the participants of the war games for this financial services firm.
But they take comfort in being prepared for an upcoming crisis.
Is your firm ready?
When the social party grows up, what if no one attends?
Posted by belbey in Actiance, Collaboration, Compliance, eDiscovery, Employee Behavior, Enterprise 2.0, Financial Services, FINRA, New Internet, Social Networking, Trends on February 6, 2013
Today’s post is a collaboration between Richie Etwaru, Director, UBS and Joanna Belbey, Social Media and Compliance Specialist, Actiance
Our last blog, “Before You Go Social, Check with Uncle Sam” covered the regulatory compliance, corporate governance, and legal requirements organizations must address before deploying social collaboration, or “internal social media.” In short, we suggested firms needed to develop policies and deploy or procure intelligent software to automate the capture, archive, retain, and supervise business communications across the enterprise.
We received material feedback. Readers reminded us that we’ve all been having the “compliance and technology conversation” around social media for some time. We aim to please so asked what’s next; we were told adoption is the biggest barrier to success. How do you make the changes to the corporate DNA to allow collaboration to flourish? In other words, how do you get adoption?
Apparently there is a party happening on grown up social networks but no one is attending.
Solving for Adoption
At the core of the thought leadership, we must look at training, sponsorship and design as three individual agendas solving for adoption. The diagram below shows three audiences for each agenda in a 3X3 matrix. The 3X3 matrix can serve as a maturity model as an organization progresses from top right of the matrix to bottom left.
Training, no one flyer fits all
There is no “one size fits all” training for employees to learn how to be “social” within the enterprise. At the one end of the audience spectrum, are employees who are adept at using social media in their personal lives. These are usually (but not always) entry-level employees. They may freely share personal experiences and thoughts with hundreds (thousands?) of their friends on Facebook or followers on Twitter. This set of employees may need to learn how to be “professionally social” within a corporate environment. There is unlearning, think first, and when in doubt resist, training needed.
In the middle of the audience spectrum training is need to inform the value of social beyond connecting people to people and content, sharing more, and the power of inviting others. For more on value beyond connecting people to people and content see “Solving for building backlash of Enterprise Social Networks” posted by Richie.
At the other end of the audience spectrum are employees who may use social media only occasionally or not at all. These are sometimes (not always) senior management. They may require a bit of handholding, and learning about specific benefits of why they should invest the time to learn something new. They also may be concerned about privacy. There is training needed to trust the platforms, learning the value of connecting to people, and benefiting by searching for and finding content in an entirely new way. This audience will not simply come to the party because they received a flyer, there is personal touch needed.
Sponsorship, they must come from everywhere
Successful deployment of social media (either internally or externally) requires commitment from senior management. However senior managers are unlikely demonstrators of sponsorship for social. Demonstrating sponsorship for social means using it, and many (not all) senior managers lack the time, commitment, and authenticity (don’t take it to heart, being authentic on social is an art, even if you are an inherently authentic person) to truly be social.
Sponsors of social medial must come from all tranches of the organization. The trusted employees, and employees that are opinion leaders can demonstrate sponsorship driving adoption. The trusted must create content, celebrate others, and invite opinion leaders (many times openly). Opinion leaders must share content of others, invite the unlikely senior managers (yes, sometimes openly as well), and advocate for the value of media other than text (such as videos) by using said new media. Finally, senior managers who are seen as unlikely adopters by the masses must be authentic. The unlikely audience should upload photos (authentic photos, not the boring corporate headshots), celebrate the opinion leaders, and share information created by the trusted.
This type of sponsorship and authentic adoption up and down the corporate ladder enables organizations to influence with sponsorship. After all, well attended parties are sponsored.
Design, customize the user experience
Inarguably, social can be separated into the believers, the voyeurs and the nay-sayers. The believers get it, and the current design of social works for them. Empower your believes, celebrate them, and hope that you can challenge them.
The voyeurs are the folks that come to the social platform, look around and leave (people that peek into restaurants or lounges and then keep going). Why do they do this? Many times it is because they “see no value when first logging into a social platform”. For us believes we ask, “really no value?” The fact is voyeurs do not see value when logging in initially, this is because they are not a part of any group, haven’t liked anything, haven’t created any content or commented or shared. Of course they see not value, the initial social experience is empty! Organizations must design social platforms to demonstrate value to voyeurs. We know who said voyeurs are, who they work for and who works for them, their peers constitute their implied social graph. We know what groups their “social graph” are in, what documents and topics their social graphs are interested in, and what questions their social graph have asked and answered. The design of the social platform should suggest a curated environment for the voyeurs on first login based on the activity and preferences of the implied social graph. When a voyeur logs in, if he/she accepts all curated suggestions, he/she will “LEAP” onto the social platform and see immediate value. This is an example of what we mean by enabling adoption with design.
Closing
This conversation can be detailed into a longer discussion, but at the heart of it, adoption is not unsolvable. There is a party happening on the grown up social networks and if no one is coming to the party we have to think like nightclub owners; guide with training, influence with sponsorship and enable a good experience with design.
Keeping it clean
Posted by doates in Employee Behavior, Social Networking on February 1, 2013
Two freedom of information requests reported in the last couple of weeks reveal that in the last few years staff at both the Department for Work and Pensions (DWP) and the Department of Transport (DoT) have been fired for social media misuse. Whilst the details of the exact circumstances have not been revealed, the UK Government does seem to be sending out mixed messages.
On one hand in its guidance to civil servants issue in May last year it cited it wanted to encourage direct conversation over social, but in response to these recent reports the DWP said that only personnel that had an absolute need were able to use it. Whilst there is definitely an argument for not enabling everyone within an organisation to have access to social media, there has to be a balance of conversation to engage with a community.
According to The Guardian, the DWP has taken disciplinary action over actions on Facebook and Twitter on 116 members of staff since 2009. Most received a warning of some type, but 11 were fired. The DoT, which has a much smaller staff level, had 25 incidents of social media misuse, which resulted in five staff being sacked.
While all employees must behave appropriately and follow guidelines, the immediate nature of social media can mean that sometimes the brain’s discretion filter isn’t always on. Organisations and businesses need to protect both themselves and their employees by ensuring that inappropriate content doesn’t end up online.
A comment made in the heat of the moment, can take on a whole new life of its own. UK PM, David Cameron only joined in the Twitter conversation late last year to a torrent of abuse in response to his first tweet. Wisely did not respond, perhaps as a result of already having to apologise in 2009 when he used bad language just talking about Twitter on live radio, the ultimate real-time communication.
Many major live broadcasts have a few seconds delay to ensure that nothing untoward goes out and enterprises have been using filters in corporate emails for over a decade. Isn’t about time we stopped sacking people for their own stupidity on social and try and provide them with tools to ensure they don’t cause offence in the first place?
What to do when social goes bad: The Lesson of HMV
Posted by SarahActiance in Actiance, Compliance, Employee Behavior, Social Networking on January 31, 2013
It’s been a momentous day in the Twitterverse for HMV. (For those of my US colleagues, who don’t know the brand, here’s a snapshot – from Wikipedia.. if you want more, click on the links).
HMV Group PLC is a British multinational entertainment retailing company with operations in the United Kingdom, Hong Kong and Singapore. It was listed on the London Stock Exchange and was a constituent of the FTSE Fledgling Index. The first HMV branded store was opened by the Gramophone Company on Oxford Street in 1921, and the HMV name was also used for television and radio sets manufactured from the 1930s onwards.
HMVSite Down
Now I had to go to Wikipedia to tell you more about HMV, because the company was put into administration on January 15th, as you can see from this is all I get at www.HMV.com
As if that isn’t bad enough, what took place on Twitter earlier today should give any senior management team cause for social cold sweats. Normally it’s great for the brand when you’re live tweeting an event (like we did recently at #IBMConnect)
But I’m not sure anyone has tweeted their own sacking before. That’s right. Just before 130pm local time, HMV’s official and verified Twitter account sent out the following: “We’re tweeting live from HR where we’re all being fired! Exciting!! #hmvXFactorFiring“.
This tweet went viral with over 1,300 retweets in 30 minutes.
This tweet was followed by 7 others, which told the social world what was going on.
Posts such as: “There are over 60 of us being fired at once! Mass execution, of loyal employees who love the brand. #hmvXFactorFiring” and, “Sorry we’ve been quiet for so long. Under contract, we’ve been unable to say a word, or -more importantly – tell the truth #hmvXFactorFiring.” Went out. And a little bit like car crash TV, we all watched.
Here’s the one that really consolidated for me the difference between those who “get” social and those who don’t. “Just overheard our Marketing Director (he’s staying, folks) ask “How do I shut down Twitter?” #hmvXFactorFiring.”
It gets worse. Several hours later the offending tweets disappeared from the @HMVtweets feed.
Not, though before you could pick them up on places like Topsy – the news and screenshots of the offending tweets have been trending through the Huffington Post, CBS and Business Week here in the US, and the story continues.
You can see more write ups of the story at Holtz Communications, TwoFourSeven and I found the news out through superstar @rhappe tweeting it (follow her, she’s great for breaking news like this)
So what can you do to make sure that #hmvXfactorFiring doesn’t end up at your door?
- Social has GOT to be part of any crisis management communications plan. Period.
- Make sure ownership of your Corporate Social Network Accounts is with a group that is part of the planning.
- Transparency is key. If you spin, lie or cheat, you will be found out.
- Deleting content, while it might be necessary sometimes (racist commentary, profanity and the like that you do NOT want on your Twitter feed have no place staying there in order to be transparent) should be undertaken with caution.
- If you do delete content, make sure you have a record of it. You can be sure that the rest of the world already does.
- Engage, understand the mood and the sentiment of the audience and go with it. Empower the team responding to do just that. Respond.
What else would you add to how you can deal with social in a crisis?
Content Can’t Take A Vacation (Or Even A Sick Day!) #TLTActiance
Posted by belbey in Actiance, Employee Behavior, Enterprise 2.0, Financial Services, Google, Guest Post, New Internet, Social Networking on January 31, 2013
Today we bring you the first of a new series on the Actiance blog: Thursday’s are “Thought Leader Thursdays” (or #TLTActiance). I’ll preface this by saying that the content is entirely that of our thought leaders, who come from all over the world, the industry and from different areas of business.
Our inaugural blog comes from our good friend and colleague in the industry, April Rudin, who you may know from @TheRudinGroup. April writes and blogs extensively, in and around the financial services space. She’s well known for her blogging on @huffingtonpost and you’ll see her at most of the financial services events especially on the East Coast of the USA.
Enjoy the blog! Sarah Carter
One of the most frequent financial advisor/wealth manager miscues in social/digital marketing is the lack of a content calendar or a basic marketing plan. It amazes me how the “planners have no plan” when it comes to new client acquisition or retention. Many people approach it almost impulsively, like opening up a Twitter account, without any clue about how to use it, what their messaging should be, or even an avatar/photo! What’s more, this “play” or experimentation is happening on the most visible amplified platform possible: the internet.
Ugh! How can you avoid embarrassing “Social Media Hall of Shame?” In this blog, I will discuss one aspect which is importance of on-going consistent and constant content. While there are plenty of mistakes and faux pas to make, the easiest to avoid is the “content vacation.” To me, this is the most egregious “offense” and it discredits the firm/advisor to existing/potential clients in the worst way: not following through with a plan. Here are a few examples. An advisor opens a Twitter account, begins following friends, or anyone, and has one solo tweet, something like “I am on Twitter now”. That was last January. The Twitter account has sat vacant since. Isn’t it suggesting that the advisor may behave that way with my assets? Another example is the blog which is posted inconsistently, i.e. January, February, March August, November, (you get the idea!). The “Hall of Shame” blog topics are without any thread linking the blog to the firm or to each other, and, perhaps the blogs were part of a one-time newsletter which has never been repeated again.
Ugh! Ugh! Developing a compelling content calendar can be very helpful in staying on track and on-time. To create an actionable, content calendar, you need to determine: What is the content? Who is the audience? Which platforms will be used? And who is responsible for what? Accountability is the key to creating a system, process for the positioning of your personal and firm’s brand on a regular basis in a way which leads back to you, your firm and new/more AUM.
I asked Kathleen Pritchard, Director and Head of Advisor Development for Legg-Mason about the importance of good, consistent content. Kathleen remarked, “While financial advisors may have limited time and resources, it’s the differentiated content which will attract and engage with your audience.”
Kathleen and I both agree that one way to create a compelling content process to include curating content from guest bloggers such as other trusted advisors is one way to “pepper” your blog with interesting stories tied to the calendar. An example would be to calendar a tax attorney to write a “year-end” blog. Inviting other third-party experts will also assist in your outreach as the contributor is likely to send your blog out within their own network as well. Repurposing the same content is another way to help and using evergreen content which is not time-sensitive can be useful in your calendar.
The brevity of this blog and the complexity of this important messaging are at odds. I have so much more to say but limited to 500 characters. Contact me.
April may be contacted via email at april@therudingroup.com or on Twitter @TheRudinGroup
Belbey Blogs: Before you go social, check with Uncle Sam
Posted by belbey in Actiance, Collaboration, Compliance, eDiscovery, Electronically Stored Information (ESI), Employee Behavior, Enterprise 2.0, Enterprise IM, Facebook, Financial Services, FINRA, Guest Post, Legal, Social Networking, Unified Communications, Web 2.0 on January 30, 2013
Today’s post is a collaboration between Richie Etwaru, Director, UBS and Joanna Belbey, Social Media and Compliance Specialist, Actiance
It’s difficult to debate the value of installing enterprise social networks.
Richie Etwaru, a futurist and avid speaker, covered the current state, business value, and future thinking needed around the construct of what he phrases the #ENTSOCNET (an internal enterprise social network). Mr. Etwaru titled the piece Solving for building backlash of Enterprise Social Networks and covers the 1st, 2nd and 3rd generation of the #ENTSOCNET. Installing an internal social network, driving, adoption and extracting business value as Mr. Etwaru describes, is complicated and difficult work. Leaders must ensure that said complicated and difficult work is being done under the auspices of regulatory guidelines.
There are regulatory compliance, corporate governance, and legal requirements organizations must address before deploying social. There however, is an impedance mismatch and some amount of misinterpretation between what the regulators consider enterprise social media, and what leaders in the enterprise consider to be enterprise social media. The spirit of the regulations suggest that whether an enterprise in installing an internal social network (what Mr. Etwaru describes as the #ENTSOCNET) for its employees only, or leveraging external social networks such as Facebook, LinkedIn or Twitter; all communications, messages, inboxes, comments, endorsements, DMs, tweets retweets etc. are governed under the regulations.
What Regulators want
More than 2 years ago, regulators of the securities industries began to issue guidance on how to use social media. The Financial Industry Regulatory Authority (FINRA), The Securities and Exchange Commission (SEC), Investment Industry Regulatory Organization of Canada (IIROC), National Association of Insurance Commissioners (NAIC) and others view social media, whether it’s external or internal, as just another form of business communications, such as email or instant messages. They remind us that it’s the content that is determinative, not the platform. Regulators also expect that firms demonstrate that they are supervising, or reviewing, a pre-defined portion of these communications. Other more general legislation may also apply such as Sarbanes-Oxley (SOX) Gramm-Leach-Bliley Act, and the data breach notification laws (PCI, DSS).
What this all means
In short, whether internal or external, firms need to ensure that all business communications (or “business as such”) are captured, archived, supervised and made easily e-discoverable. There is nothing new here as this has been an evolution. First paper, then email, instant messages, now both internal and external social media, firms continue to be challenged to capture, retain and review a portion of all business records in whatever form they appear. As a first step, firms may use their existing email and instant message retention policies as a framework to develop policies for internal and external social media. Governing said policies is a separate and pronounced challenge.
Governance is key
Firms are increasingly committed to comprehensive corporate governance to avoid scandal and to comply with regulations. The development of sound policies and procedures before deployment is key, given the vast amount of data stored in most collaboration environments and the free ranging conversations among employees, contractors and even clients that can ensue, policies must be defined.
Specifically policies should address: records management (retention, litigation readiness, privacy), information management (making sure that records are tamper proof, and easily accessible), data deposition (disposal of data) and conflict management. Where possible, firms should automate policies with technology to protect their intellectual property, prevent the creation and distribution of inappropriate content and provide an audit trail of all activity to ensure accountability.
It’s a serious legal matter
When learning of pending litigation, firms must be able to preserve all records (“legal hold” or “ligation holds”) that may relate to legal action against the company, including records of social activity. According to the Federal Rules of Civil Procedures (FRCP), firms must meet discovery requests for paper as well as electronic documents (spreadsheets, slide decks), emails, posts, and conversations across social media in a timely fashion. Therefore, firms need plans and the means to retain and produce such data upon request. Email was new and difficult, social is not yet understood, complex and mindboggling.
Social, not my grandma’s email
Social media, due to its nature, adds complexity to these requirements as interactions occur over time. For example, a blog starts with an initial post, then readers may add comments, or change their minds and revise and delete their comments and the original author may respond. These interactions could go on for months in some cases. Firms should have the ability to produce all of these threads of posts, comments and replies “in context” to give meaning to the conversations. By providing context, firms may reduce litigation costs by reducing the number of hours required by attorneys to sort through records to determine the sequence of events and the true essence of the conversations. Preserving context requires intelligent software solutions.
What now
Enterprise-wide “social business” tools were designed to facilitate collaboration, not necessarily to meet the legal and compliance requirements of regulated firms or public corporations. They offer basic functionality to capture and archive communications, but not the reporting, contextual view of information, nor granular policy setting that may be desired. Firms are therefore advised that before deploying enterprise wide collaboration tools, they look to third party vendors to ensure their compliance requirements are met.
Collaboration, no pun intended
I reached out to Mr. Etwaru (whom I met a few years ago at a conference in NYC) and shared this perspective. His response is below.
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Hi Joanna,
Your thoughts are spot on. From the regulators (who are doing a great job) point of view social, email, chat, etc. all carry similar risk and hence are metaphorically bucketed from a guidance standpoint. In the enterprise however, the risk with social is multiples higher for a multitude of reasons. One reason is employees learned of social in their personal lives where regulations are by and large absent. Hence, when using social in the enterprise (or in a commercial manner) employees (fallible as we are) tend to assume the same “free range” comes with social. The policy, governance and education you suggested is paramount, I could not agree more.
That being said …
However daunting all of this may be, the biggest risk is not using internal social media to break down silos and to unleash the intellectual power of the enterprise while driving innovation.
BTW, love your diagram, I can help you make it pretty
Hope this helps,
-R
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Diagram above rendered by Mr. Etwaru,
-Joanna
Belbey Blogs: New Guidance on Using Social Media at Retail Banks
Posted by belbey in Actiance, Collaboration, Compliance, eDiscovery, Electronically Stored Information (ESI), Employee Behavior, Enterprise 2.0, Enterprise IM, FFIEC, Financial Services, FINRA, Legal, Malware, Privacy, Retail banking on January 25, 2013
This week, the Federal Financial Institutions Examination Council (FFIEC) released “Social Media: Consumer Compliance Risk Management Guidance. The FFIEC is asking for comments within sixty days. You can download the 31-page document here.
Its release has created quite a stir within the banking industry. A comprehensive article appeared on TheFinancialBrand.com, “Regulatory Shocker on Social Media in Banking Coming Soon” that summarizes the guidance quite nicely.
But . . . what’s so shocking?
We’ve been having the same conversations in the securities industry for three years. And in those three years, firms have learned that there are three major areas of risk that need to be mitigated before deploying social media:
- Security: your IT department needs to prevent your firm’s proprietary and client information from being leaked out either inadvertently or maliciously from the enterprise. They also need to ramp up malware protection. That’s because social media users are susceptible to incoming threats as they view themselves as part of a tribe and tend to click on any link sent by a “friend.”
- Compliance and Governance: your legal and compliance departments already know that there are thousands of rules and regulations that govern the communications and advertising of publicly held corporations, firms in general, and bank specifically. Take the securities industry as an example – the banking regulators aren’t issuing new rules and regulations around social media. Social media is viewed as just another form of written communications. Your compliance department is therefore challenged to interpret existing rules as they apply to social media and to develop and enforce firm policies.
- Enablement: your executive team is concerned about productivity and the bottom line. Now that every employee can be the face of the business, you either have a powerful marketing tool or your worst nightmare. Employees will need to be trained on how to use social media effectively to meet the firm’s goals, such as nurturing existing clients, attracting new business, recruiting, and brand awareness.
However, during the last three years, we’ve learned that all these risks can be mitigated by strong corporate polices, backed up with technology and training.
So far, so good. Nothing new here. Or is there? In addition to what we’ve already seen from other regulators, the FFIEC specifically also calls for:
- Creation of policies to address negative feedback or customer complaints, even if a financial firm chooses not to actively engage in social media.
- Monitoring to protect the firm’s brand identity
- Due diligence and oversight for third-party vendors that firms may hire in connection with social media
And the one that I find most interesting:
- Processes and reporting to demonstrate how social media “contributes to the strategic goals of the institution.”
In other words, the FFIEC recommends that firms measure the ROI of social media.
It will be interesting to see the reaction that FFIEC gets from the industry. I just hope that the banking industry can use some of the key learnings from the securities industry to streamline the processes to reap the benefits of “getting social.”
For more details on how to deploy social media within retail banking, you can also check out Belbey Blogs: Upcoming Guidance for the Use of Social Media for Retail Banking from FFIEC.
