RegEd Social Media Basics Webinar Series - the social media policy

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

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Social Media PolicySocial Media Basics Webinar Series

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Getting Started on Social is driven by strategy and policy

Who, What, When, Where and How?

Your Policy is a Business Plan AND Governance Document

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Social Media Policy Best Practices

Define and Document Your Policy

Who is authorized?

Which platforms are acceptable?

Include your own governance and ethics

Approved technology

Signed affirmations

Mitigation

Ongoing management

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Scott PetersonCo-Founder703.722.6688 (office)571.344.4446 (cell)www.relaystationmedia.com/ | @sthepetersonwww.linkedin.com/in/scottthepeterson www.signalboost.com Blog

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Dummy textSocial Media Is About Sharing

Learning, Engagement, Conversation, CommunityYour policy shouldn‘t be too restrictive about what is shared!

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Elements of Social Media Policy

At work:• Mandatory training to use social media• Mandatory use of archiving and review system• Permitted & prohibited platforms• Right to remove content on company systems• Right to monitor employees• Annual policy certification by all employees• And more

At home:• Right to monitor any comments about company on Internet

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Web site and blog

Social Platforms

Digital Marketin

g Digital Events

(webinars)

Hub and Spoke Model

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PlatformsLeverage flexibility of multiple mediums & formats

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The Gateway to Social Media For All

Tablets Smart Phones

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Governance

Outline regulations to meet

‒ Retention and Surveillance

‒ Review and Monitoring

‒ Broad Search – rogue accounts, complaints…

Written Supervisory Procedures

Lexicons and Searches

Pre-Approving Content

Identify FINRA & SEC Rules that Apply

Define Monitoring Methods

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Choosing Technology

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• How will you collect data?

Data Aggregation & Retention

• How will you supervise content?

Reporting Automation

• How will you search for what you “don’t know”?

Monitoring

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Rules & Regulations

FINRA Guidance (10-06, 11-39, 12-29)

NASD 2210(b) & 3010

SEC 17a4, 206(4)-7

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Social Media Policy Is a Regulatory Requirement

SEC Rule 206(4)-7 Firms must adopt and periodically review effectiveness of policies and procedures regarding social media.

FINRA Reg Notice 10-06Firms must have a general policy prohibiting any associated person from engaging in business communications in a social media site that is not subject to the firm’s supervision… only those associated persons who have received appropriate training … may engage in such communications.

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Dummy textSection 7 of National Labor Relations Act

Employees have right to participate in “concerted activities for the purpose of collective bargaining or other mutual aid or protection.”

Prohibiting statements that “damage the company” is too broad a restriction.

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Dummy textSection 7 of National Labor Relations Act

Be specific!Include reference that your policy does not include protected activitiesList 19 other categories of behavior can be prohibited

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Social Media Basics Webinar Series

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