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Risky Business
Rebecca H. Davis
Lisa Thurber
Wal-Mart Stores, Inc.
DON’T BELIEVE THE HYPE
CHALLENGE OR OPPORTUNITY?
Source of Risk
Risk Mgmt Tool
RISK MANAGEMENT
THREAT X VULNERABILITY = RISK
LEGAL/REGULATORY REPUTATIONAL OPERATIONS
Privacy and security
laws and regulations
Employment law
Labor law
FTC Endorsement and
Advertising Guidelines
Copyright and
trademark violations
Securities laws
FCRA
Defamation
Stakeholders
– Customers
– Employees
– Suppliers
– Critics and endorsers
– General public
Fraud & brand identity
IT security
Loss of IP (trade
secrets, etc)
Worker productivity
Hostile workplace
Hostile customer
environment
RISK MITIGATION
5 10 15 20 25
4 8 12 16 20
3 6 9 12 15
2 4 6 8 10
1 2 3 4 5
4
Likely
5
Almost Certain
2
Unlikely
3
Possible
IMP
AC
T
LIKELIHOOD
5
Sig
nif
ica
nt
4
Ma
jor
3
Mo
de
rate
2
Min
or
1
Slig
ht
1
Remote
Terms of use and community guidelines
Governance
Policies and procedures
Employee training
Incident response
Vendor diligence
Audit and compliance
Feedback and reporting
CASE STUDY:
WALMARTONE
Associates are our best reputation ambassadors
DOES ANYONE ACTUALLY USE WALMARTONE?
• over 1 million registered users…and growing daily
• U.S. associates from Walmart and Sam’s Club
• 15 million page views in December 2012
• 85% of users return to the site 3x or more each week
• site activity is from at-home users – “off the clock” access only
REAL CONVERSATIONS FROM REAL PEOPLE
What do you think
should be done about
the debt issue?
What’s the
weirdest question
you’ve ever gotten
from a customer?
Anyone going back to
college? How do you
balance work, school
and family?
LGBT at Walmart?
Are you out at work?
To family and friends?
REAL CONVERSATIONS? WAIT A MINUTE.
You let them talk about whatever they want? (pretty much)
Don’t you have to approve comments first? (nope)
What if they say something negative? (comes with the territory)
How do you keep them from talking about sensitive issues?
(we don’t!)
Q: How’s that working out for you?
A: Great. Content Moderation and Community Guidelines are active on the
site 24/7
CONTENT MODERATION
Process documentation for the Legal team: English translation for the rest of us:
Active Moderation for new topics
Passive Moderation for comments
Language filter for everything
Associates can report comments
they feel are inappropriate
Legal and Ethics follow up, when
needed
MORE LEGALESE!
Community Guidelines crafted by legal and
approved for posting on a website owned by
the world’s largest retailer.
Guess how lengthy and complicated that document is.
ONE SHORT, EASY TO UNDERSTAND PAGE OF RULES
Community Guidelines on mywalmart.com
Mywalmart.com was made for you. Almost every page has a place to share your thoughts and stories for other associates to see. Here are a few
simple guidelines to keep in mind when contributing to the site.
What to do…
•Share your thoughts – We want to know what you think. Join the conversations on the site.
•Stay on topic – If you join a conversation, keep your comments related to the current topic. This helps everyone follow the conversation. If the
current topic doesn’t interest you, hit the “Request a New Topic” button, and submit a new topic for review.
•Show respect – We’re all aware of the Three Basic Beliefs and the importance of showing respect for the individual. Everyone deserves that same
level of respect on the site, too.
•It’s ok to disagree – We don’t all see eye to eye on everything. Wouldn’t that be boring? If you disagree about something posted, say so. Just
remember to do it in a respectful way.
•Have fun – Enjoy and make this your site. Get involved. Share your thoughts and experiences. Learn what others think and join the conversation.
What not to do…
•Don’t break the law – Don’t post anything that involves or promotes illegal activity.
•Don’t be mean – Don’t post anything obscene, lewd, discriminatory, or anything intended to harass someone. And don’t gossip about other
associates.
•Don’t take your work to the site – This site is not for chatting about setting that new modular or discussing the wonderful P&L report you’re
creating. There’re plenty of other topics to learn about and discuss on the site. Leave your work at work.
Still have questions or concerns…
If you’re unclear about what’s appropriate for the site, refer to the site’s Terms of Use and our Social Media Policy.
If you run across any inappropriate content on the site, you can use the “Report as Inappropriate” button to let us know.
Content reported as inappropriate twice by the community is automatically pulled from the site for review.
…and yes, these really are the actual “rules” for the site.
ONE EXAMPLE OF HOW SOCIAL MEDIA BENEFITS THE BUSINESS
Social interactions between associates and Benefits SMEs during Benefits
Annual Enrollment helped create a 14% reduction in call center traffic.
SOURCES & ADDITIONAL READING
Weber, Alan, Guarding the Social Gates, the Imperative for Social
Media Risk Management, Altimeter Group (August 9, 2012)
Merrill, Toby et al., Social Media: The Business Benefits May be Enormous, But Can the Risks – Reputational, Legal, Operational – be Mitigated? Information Law Group and Ace (April 2011)*
Tomhave, Benjamin, Scaling Risk Management, ISSA Journal (November 2011)
Penenberg, Adam, Social Media Affects Brains Like Falling in Love, Fast Company (July 21,2010)*
Social Media: Consumer Compliance Risk Management Guidance FFIEC notice; request for guidance, Federal Register Vol. 78, No. 15 (January 23, 2013)*
NLRB Memorandum OM 12-59, May 30, 2012*
*URLs provided on notes slide
BACK AT THE OFFICE…
Risk Management Tool Source of Risk
First Things First!
1. Conduct general risk assessment
2. Analyze social media’s strengths against organizational needs
a) Visibility into offline issues b) Reputation ambassadors c) Collaboration tools d) Crisis/event prediction
3. Develop leverage plan
1. Take stock of current controls
2. Develop organization-specific catalog of threats and vulnerabilities
3. Conduct risk assessment
4. Develop work risk treatment plan
1. Who? Identify stakeholders (RACI) and social media users.
2. What? Survey social media in use or planned.
3. How? Assess attitudes toward social media, risk appetite, and resources.
4. Why? Define strategy and purpose for company social media.