Archive for category Enterprise 2.0
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?
SEC Clears Social Media for Use: What does it mean?
Posted by SarahActiance in Actiance, eDiscovery, Enterprise 2.0, Facebook, Financial Services, Google, LinkedIn, personal v professional, Retail banking, Securities and Exchange Commission, Social Networking, Trends on April 16, 2013
On April 2nd the SEC issued a press release, which has been widely reported in a number of ways, as to what this actually means for organizations. In this blog, lets take a look at what it actually means.
WHAT DOES THE SEC SAY?
Here’s what the SEC actually says “companies can use social media outlets like Facebook and Twitter to announce key information in compliance with Regulation Fair Disclosure (Regulation FD) so long as investors have been alerted about which social media will be used to disseminate such information”.
The exact text is on the SEC website: http://www.sec.gov/news/press/2013/2013-51.htm We’re pleased to see that the content was tweeted as well. Interestingly, it was in 2008 that the SEC actually cleared the use of websites for the dissemination of key information. It feels like its been a long five years to get the same clearance for social media. But perhaps not. On August 6th 1991, some 17 years earlier the first website was born, at CERN – the first URL for that website was http://info.cern.ch/hypertext/WWW/TheProject.html in case you want to check it out. So, it appears progress is being made. Our world is speeding up.
WHAT DOES THAT ACTUALLY MEAN?
- It means that, so long as a public company announces in advance, what social outlets they will use, that they are able to disseminate key information through these channels.
- In general, key information is usually mailed out or put on a wire service like Marketwire or PR Newswire and also onto the company website.
DOES THIS MEAN THAT THE FINANCIAL SERVICES INDUSTRY WILL NOW ALL BE ON SOCIAL?
- Not necessarily, it doesn’t meant that individuals in companies will necessary be all now posting content through their individual network updates.
- It does mean that firms will need to open up access to social media so that Financial Advisers, Relationship Managers and those assisting clients with investment information can access this information – it really IMO opens the floodgates for firms now saying, that if you have financial professionals who need to keep up to date with key publicly traded companies, then they need to see this information. If you don’t, then it would be like forbidding a professional to read the newspaper or watch TV.
- Usually when public companies distribute key information like this, they distribute it through a “corporate property” – in social terms this would be the company Facebook page, or the company Twitter account, or the company page on LinkedIn.
- Record retention requirements means that companies will have retain records of what they posted. i.e. LinkedIn company updates.
WHAT DOES IT MEAN TO THE DISTRIBUTED TEAM?
- It means that they will require access to social in order to conduct their work effectively.
- As a result of the SEC’s ruling, anyone that needs to keep an eye on key information from public companies will NEED to have access to social in order to remain competitive.
- The socially savvy public company will use individuals to push this content out, along with corporate brands. Take Reed Hastings of Netflix for instance – this whole thing started because it was HIS Facebook page, not the company page.
WHAT DOES IT MEAN TO FINANCIAL SERVICES FIRMS and PUBLIC COMPANIES?
1) Archiving company updates for public companies will become a must have. Public companies will need to archive the company updates and any other updates that are related to Regulation FD.
2) Ensuring that the right person / people approved this content is key. They will need to prove that it was approved by the relevant individuals/groups in the organization.
3) Companies may choose to share content to a “Shareholders Group” on LinkedIn, a group on Facebook, or a private feed on Twitter, thus requiring that content is approved and archived, is again key.
4) Some companies might select individuals to share this key information – so ensuring that the content is again approved and archived is key. However, the SEC points out, that “The report of investigation explains that although every case must be evaluated on its own facts, disclosure of material, nonpublic information on the personal social media site of an individual corporate officer — without advance notice to investors that the site may be used for this purpose — is unlikely to qualify as an acceptable method of disclosure under the securities laws. Personal social media sites of individuals employed by a public company would not ordinarily be assumed to be channels through which the company would disclose material corporate information.” So ensure prior notification has been made – and that it is clear, which channels and which accounts will be used to disseminate this information.
5) Those firms that block social access for the wider team will not be evaluating their policies, in order to provide open access to at least view for instance LinkedIn news and company updates while on corporate machines.
6) Social networks outside of Facebook and Twitter should be lobbying the SEC – who referenced only Facebook and Twitter – but not LinkedIn as social channels. LinkedIn is the network that most business professionals feel comfortable with and with whom they connect with business colleagues on much more than Facebook and Twitter. It’s clear that the SEC needs to understand the company area of LinkedIn, but also the value of the personal network – using the Reed Hasting’s example – if he had used his LinkedIn network update to push this out, it would have had the same effect as he did with Facebook.
WHAT SHOULD YOU DO?
1) Review your social policies, both for listening, and for distributing content. This great move by the SEC has opened the way for “no business reason for social” to be removed. Ensure that you’re including all the stakeholders into this review.
2) Ensure, if you are a public company, that any content you are sharing on social – goes through the same approvals that content for other mediums does. Archive it and retain it.
3) Embrace this new communications modality approval by the SEC. Those who disseminate key information in compliance with Regulation FD, through social channels, will certainly be in the forefront of the press and generate those softer elements of ROI, that we all strive for. So make sure you take this into consideration when you’re looking at the benefits of social.
Let me wrap up by asking a question. If you were to choose one social channel to share key information.. what would it be?
Belbey Blogs: Recent Guidance from the SEC on Filing Social Media
Posted by belbey in Actiance, Compliance, eDiscovery, Electronically Stored Information (ESI), Enterprise 2.0, Financial Services, FINRA, Securities and Exchange Commission, Uncategorized on April 2, 2013
Today’s blog is from Joanna Belbey, Social Media and Compliance Specialist at Actiance.
This month, the Division of Investment Management of the Securities and Exchange Commission issued the first in a series of “IM Guidance Updates” to clarify its positions on emerging legal issues. The first topic was social media.
Financial services firms are cautious by nature, and its both our experience and no surprise, that firms are taking a very conservative approach and are filing a huge amount of social media content with FINRA. The SEC is calling out that this may be unnecessary in a number of cases.
First some background. To ensure that communications from financial institutions are suitable, fair and balanced, the FINRA Advertising Regulation Department reviews the content of more than 100,000 communications every year. Some communications are submitted as required by FINRA rules, others are submitted voluntarily. Some are filed in advance, others within 10 days of publication. However in FINRA Rule 2210(c)(7)(M), effective February 2013, retail communications posted on an “online interactive electronic forum that is contained on a social media website” are specifically excluded from these filing requirements.
However, as firms have other filing requirements aside from FINRA, such as Section 24(b) of the Investment Company Act of 1940 (“1940 Act”) or Rule 497 under the Securities Act of 1933 (“1933 Act”), SEC has seen fit to provide guidance on what should and should not be filed.
As the SEC states “Whether a communication need be filed depends on the content, context, and presentation of the particular communication”. So nothing changes there. This is simply reiteration. But now the SEC goes a little further. The more specific, the more likely it needs to be filed. And as an aside, whether the communications are filed or not, they still need to captured, supervised, archived, made e-discoverable like any other written communication for “business as such”.
The SEC provided some examples for clarity:
Do Not File
- Simple mention of a specific investment company or family of funds without discussion of merits
- Mention of word “performance” in connection with a specific investment company or family of funds without mention of returns
- Factual introductory statement / hyperlink to fund prospectus (ie, report available here)
- An introductory statement not related to investment merits of a fund that includes hyperlink to general information
- Response to an inquiry via social media that provides factual information and does not include merits of the fund
File (to meet requirements of Section 24(b) or Rule 482):
- Discussion of fund performance that provides specific mention of fund’s returns
- Issuer communications that discuss merits of an investment fund
The regulators continue to reinforce what we know to be best practices of social media. Pitching financial products, and discussing specific performance and returns is unwelcome on social media and may require pre-approval by a registered principal of the firm as well as filing requirements.
A better approach?
Provide compelling content, not sales pitches. Offer information that is informative, entertaining, and worth sharing. In a compliance-constrained industry like financial services, delivering compelling content can be challenging, but it’s by no means impossible.
The first step is to inventory your existing content to see what can be leveraged for social media. Start with pre-approved content that has been reviewed by the company’s compliance team for both corporate governance and regulatory compliance. Use this content to develop a library of interesting insights on investment strategies, wealth management, saving for college or retirement, and similar topics. These articles can provide a foundation for social media newcomers who are looking to start building their online networks.
This Spring is a great time to get started!
Other information you may find helpful:
Belbey Blogs: New FINRA Communications Rule 2210
http://blog.actiance.com/2013/02/13/belbey-blogs-new-finra-communications-rule-2210/
Division of Investment Management of the Securities and Exchange Commission Issues Guidance Update on Social Media Filings by Investment Companies
http://www.sec.gov/news/press/2013/2013-40.htm
IM Guidance Update March 2013
FINRA Rule 2210
http://finra.complinet.com/en/display/display_main.html?rbid=2403&element_id=10648
Regulatory Notice 12-29 Communications with the Public
http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p127014.pdf
Regulatory Notice 10-06, Social Media Web Sites: Guidance on Blogs and Social Networking Web Sites (January 2010)
http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p120779.pdf
Guide to the Web for Registered Representatives
http://www.finra.org/Industry/Issues/Advertising/p006118
FINRA: RCA – March 1999 – Ask the Analust – Electronic Communications
https://www.finra.org/Industry/Regulation/Guidance/RCA/p015326
Belbey Blogs: Disconnected from Customer Service? Better Start Tweeting!
Posted by belbey in Enterprise 2.0, New Internet, Social Networking, Trends, Twitter, Uncategorized on March 18, 2013
Awhile back, I received a special promotion from the Big Telephone Company (BTC) for blindingly fast internet, telephone and cable. For less than the Big Cable Company (BCC)! Sounds good, I’ll take it.
I called the Sales Department to sign up, but was told, “Sorry Ms. Belbey. That service is not available in your area.” “But I received a letter!”, I exclaimed. Hmmm. Why on earth wasn’t my zip code suppressed in the mailing? Disconnect #1: Personalized direct marketing campaign didn’t match service availability.
Ok fine. I decided to go ahead with phone and internet. I explained that although there was a jack in the bedroom, I wanted my phone and internet in the living room. (Yes, I know that I could use a cordless phone, or wifi, but I want to plug in.) Therefore, I needed a technician to install a jack.
A technician arrived, plugged the router into the jack in the bedroom and told me I was all set to go. I explained again that I needed a jack to be installed in the living room and the technician explained, “I don’t install jacks, call Customer Service”.
So I called Customer Service and set up an appointment. A router arrived by mail, I received a voice mail confirming the appointment and another voice mail congratulating me on my new service. But no technician. That happened three times. Disconnect #2: Lack of communication between departments.
At this point, I gave up, called BTC and told them to forget it. I also asked for some mailing slips and boxes to return their four routers. I shipped them back and thought it was over.
I received bills during this time, but ignored them as I thought I didn’t owe anything as I never accessed the system. I assumed there was a disconnect with Billing too. But, next thing I knew, I received a letter from a collections agency.
Yikes! I called Customer Service again, determined to resolve this once and for all.
Over the course of a 90-minute phone call, I escalated the issue three times until I reached a “manager” who wasn’t reading from a script. She bordered on nasty. She said that she had no record of my multiple interactions and that in order to cancel the service, I would need to pay the bill in full, contact Billing and all three credit agencies. Huh? She assured me that I would receive some credit at some point. In essence, she had me over a barrel. And she knew it. To protect my credit rating, I reluctantly mailed a check. Disconnects #3, #4 and #5: No access to customer records, lack of common sense, lack of respect for a customer with an existing account for 30+ years.
During that 90-minute phone call, I started tweeting very politely at BTC asking for help. Within moments, I received a perky reply (How can we help? We’re here for you!) and was asked to direct message (DM) the issue. After a few DMs, I received a link to file a compliant, and even another upbeat tweet to make sure I was able to submit the form. Within 24 hours, I received a phone call from a lovely women from the “Presidential Escalation Response Team”. It was as though I was talking to two very different companies. She had done her homework. She asked me in her broad New Jersey accent, “Let me see if I got this straight. You were billed for a service you never used, your account’s in collections and you want to cancel the service and get your money back and have no problem with your credit. Did I get that right? “Yup, that’s it”, I said.
“No problem! I’ll fix it”. And she did.
Disconnect #6: Frustrating, time consuming traditional customer service in stark contrast to responsive, smart and friendly customer service via social media.
It was clear that BTC had hired, trained and empowered their social media team to be customer-centric. They were friendly and smart and I enjoyed our interactions. Unlike their traditional customer service which was, er, less enjoyable.
No more traditional customer service for me. I’ll just tweet!
Is your firm disconnected?
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.
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.
~~~~~~~~~~~~~~~~~~~~~
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
~~~~~~~~~~~~~~~~~~~~~
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.
Is the World Really All Blue?
Posted by SarahActiance in Actiance, Employee Behavior, Enterprise 2.0, Financial Services, Google, Social Networking on January 8, 2013
There’s nothing like a good healthy debate I say. So I was interested to see Jae Kim discussing right here on the Actiance Blog yesterday about the world turning Facebook Blue. As ever Jae and I like to discuss and we truly come at our discussion from differing points of view. Much like any team of stakeholders in an organization, my view is colored by my outlook, my responsibilities and my requirements, as is Jae’s.
Our view of the social world is also colored by the industry in which we live, eat and breathe. Take for instance Actiance’s markets for social media engagement and compliance – Financial Services, Wealth Management, Banking and Insurance – the world that our end users tend to exist in, is very definitely still blue, it’s just a different hue. That’s right folks, the primary network of choice that we’re seeing being used by these industries is LinkedIn and LinkedIn have done some pretty cool research on this recently..
I agree wholeheartedly with Jae that Facebook won’t replace other forms of communications, but I do have to say “tosh”* (* for those non Brit’s in the audience, that means I disagree with him) to his comment that Facebook is used primarily as a personal social network. Why? Well there’s a number of reasons (and bear in mind my opinion is more than likely based on my role and what colors me..).
1) It might be personal, but look at all the brands I engage with. Brands like the ones I’m engaging with aren’t people. It’s not personal to the brand. My engagement in the last two weeks has been with Amtrak (and I’m delighted that they re-used my photo of Donner Lake following my trip on the California Zephyr recently); Jackson Hole Mountain Resort, Yellowstone National Park, Grand Teton National Park, New York Life Insurance, .. the list goes on.
Actually though it looks like I’m in the minority. Only 1% of Facebook users engage with brands according to Adage
2) the HUGE growth that we’re seeing in engagement is about the rise of the personal brand. Take a look at @FrankEliason – orginally the character behind the 140 at Comcast, now the walking, talking, tweeting face of @Citi and the author of a superb read on customer service and Social. This is where the major growth of social usage will come from – I expect lots of this in 2013.
3) There is no difference for me between personal and professional. When I look at my Facebook account, I have well, what I’d call my personal profile (that’s me http://www.facebook.com/sarahcarterdockerty ). I have a SarahActiance business person page, but you know, there is no difference between Sarah the professional person and Sarah the individual. I live Social, so if we’re friends, if you follow, or if you’re a connection – depending on which network and what terminology you use, then what you see is what you get. I’m friends on Facebook with customers, compliance officers, journalists, analysts, as well as friends, family and colleagues. Does that help me in business? Absolutely. Only this morning, an ex colleague who I’ve remained in contact with on Facebook with since she left the company, reached out and asked if we were recruiting again; I’ve now got a “movie critics R US” session at the upcoming @IBM Connect because I’m buddies with @jakewengroff on Foursquare and we’re going to compare notes on Les Mis and Anna Karenina.
4) Is Facebook at it’s peak? Well who’s to say. There are two ways in which social networks grow – first the number of users they add, then its about the saturation of the individual users. So there will come a peak for the number of users.. but then you know this world in which we live had population growth too… but what about the way in which we use social. Has my usage of Facebook gone up over the last 12 months? Certainly. Oh most certainly. but so to has my use of Pinterest, Twitter, Foursquare and Google+. Growth for the networks themselves comes in the minutes we spend on the network and the locations we access those networks from.
5) And that’s kind of vaguely a nice segue into Google+ because it appears despite many folks best efforts to ignore Google’s n’th attempt to break down the Facebook Blue, there’s going to be no avoiding Google+ according to the Wall Street Journal’s Amit Efrati.
Well, I think 5 is just enough bullet points to invite debate. I’ll leave you with a question. What’s your most relevant social network? And Why?
Belbey Blogs: Observations from the road…
Posted by belbey in Compliance, Enterprise 2.0, FINRA, New Internet, Social Networking, Trends on November 1, 2011
As the Social Media and Compliance Specialist for Actiance, I am tasked with educating firms within regulated industries on how to use social media effectively, while meeting compliance requirements. In this role, I meet with clients, speak at industry events and am on hand to be the expert at seminars, trade shows and the like. This past few weeks, I’ve participated in lively conversations within the securities and insurance industries about deploying social media and thought I’d share what I’ve been hearing…
- When discussing book keeping requirements vs privacy issues at client meetings, several senior compliance professionals at large broker dealers have relayed that although FINRA is only interested in business communications, they plan to capture, supervise and archive all of their registered representatives’ use of social media. “How do I know that they aren’t doing business in their “personal” accounts is the question often asked? If they want to use the tools, the regulator is interested in the content of the message, not the identity that I used to post it”
- At the CEFLI Social Media – Regulatory Insights & Implementation Strategies Summit (http://www.cefli.org/events/summit-meetings/regulatory-insights-implementation-strategies) a senior marketing professional at one very large insurance firm told me that their advertising department develops content, sends it to their compliance department for approval and then adds the content to a centralized library for their producers to use. All subsequent conversations from that original content are supervised. At the same event, I learned that Facebook is the network of choice for many producers. They “friend” their clients and use “Life Events” such as getting married, buying a house and having children, as opportunities to sell insurance. I can understand that totally. Just like I understand why wealth management has great success with LinkedIn. Each market to their own network and all that.
- At the BDI Insurance Social Communications Leadership Form (http://www.cvent.com/events/insurance-social-communications-leadership-forum/event-summary-7391fdd325c149839aade4300775ba24.aspx a senior marketing professional from a global bank stated that not only is all content created by marketing and approved by legal, she personally crafts all the responses to the content for 10 Subject Matter Experts. I know for a fact, that since I, and members of the social team here at Actiance starting creating and crafting social messages, we’ve seen our organizations social interactions sky rocket. As is oft repeated in our internal meetings “ just because you give them access to social doesn’t mean that they know what they’re doing or what to share”.
- At the IQPC Financial Innovation Technology Forum (http://www.iqpc.com/Event.aspx?id=555242), one firm shared how they are using quizzes and gamification to drive revenue producing behavior. I love this and I love how gamification drives distributed teams – face it, if you’re in a team responsible for revenue you want to be the #winner so being able to see how you’re doing against your colleagues is conduicive to driving that behavior.
- And at the National Securities Compliance Professional (NSCP) Annual Conference http://nscpmeetings.com/2011/meeting-nat.html
Norv Leong, our director of product marketing, member of the California bar, legal ying to my social yang, and my booth mate for the conference were intrigued by the number of times we asked attendees whether they have social media policies in place and that they repeated “YES” Great we thought… until they added ”Our policy is no!”.
Want to know what we learned at the FINRA Advertising and Regulation Conference Stop by again shortly, and I’ll share all…
