The financial industry has been craving guidance on the use of social media for marketing purposes as well as ideas for how the social conduct of their employees can be managed. Because of this, the FFIEC recently issued guidelines financial institutions a better understanding of how to mitigate risk in interactive online social environments.
Included in this guidance, the FFIEC states that all financial institutions should provide guidance and training for employee official use of social media. They officially prescribe “an employee training program that incorporates the institution’s policies and procedures for official, work-related use of social media, and potentially for other uses of social media, including defining impermissible activities.”
How do you go about developing a program that fills this need?
The FFIEC suggests that the risk management program should be designed with participation from specialists in compliance, technology, information security, legal, human resources and marketing.
Here is a checklist of what could be included (but not required) in a social media training program for employees of financial institutions.
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Give Employees a Tour of the Basics
Most employees that have joined a social network already understand the basic concepts of online social interaction. However, not all employees may understand the various components of individual social networks. Don’t assume they know everything they should.
The first part of an employee training program should address the overall purpose and particulars of each social media account your institution maintains. Employees need to understand how the financial institution is represented on each social network, and how their personal accounts might affect the institution’s overall risk profile.
For example, on Facebook, one would want to review the various components of Facebook Timelines — where they are located, the purposes they serve and how privacy issues are addressed. If third-party platforms are utilized to build, distribute and manage content across social channels, be prepared to share information about how the system is used, by whom, why and when.
A more extensive training program would outline the institution’s specific marketing communications goals, and where social fits within it.
How Employees Can Utilize Your Social Channels
Employees may not be familiar with how their individual social media accounts affect the institution. Employees dropping seemingly harmless tweets or Facebook updates might subject the financial institution to compliance risk, operational risk, or reputational risk. Some banks and credit unions take no chances, advising employees to never discuss customer accounts on social media, nor speak on behalf of the institution unless expressly permitted to do so. Plenty take it one step further, telling employees that they shouldn’t even mention where they work (e.g., listing the bank or credit union in the employees’ social media profiles).
With proper education and training, there may be times when employees could be encouraged to share information that’s already been shared socially the institution — without any editing.
On Twitter, employees could be encouraged to:
- Follow @YourBank on Twitter
- Share the YourBank Twitter page with their friends
- Retweet tweets by @YourBank
- Share promotional hashtags branded by the Bank (when applicable)
- Send the Marketing Department ideas for photos, events, links, articles, etc. to post on YourBank’s Twitter page
- Regularly check the YourBank Twitter page for new updates about the Bank
On Facebook, employees could be encouraged to:
- Like the YourBank Facebook page
- Share the YourBank Facebook page with their friends
- Like posts on YourBank’s Timeline
- Comment on posts on YourBank’s Timeline (except in response to a customer)
- Share posts from YourBank’s Timeline with their friends
- Send the Marketing Department ideas for photos, events, links, article, etc. to post on the YourBank Facebook page
- Regularly check the YourBank Facebook page for new updates about the Bank
Each financial institution must also develop a list of actions that are not permissible by employees on social channels. This list must specify the precise consequence for these actions, whether it be a verbal or written warning, or a more extreme measure. In no way should the financial institution be vague when it comes to citing specific examples of employee misuse of social media and the resulting consequence.
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Employees will benefit from an educational session on proper online etiquette in order to fully understand what is expected of them as professionals utilizing this form of interactive media. Employees should be encouraged to:
- Keep their profile pictures professional in nature, or at least neutral. Some images on social media are always public regardless of individualized settings so that anyone can see them.
- Pay extra attention to the privacy and account settings within each network, and keep up-to-date with platform changes to help protect their online persona.
- Activate “Timeline Review” on Facebook, which requires that a person approves content that others “tag” them in before the content appears on their Timeline.
- Keep in mind the financial institution’s social media policy before taking any actions that could be considered misuse.
- Acknowledge all connection requests sent to them. If a request is sent from someone they don’t know, the request should be rejected and marked as “spam” so that the social network can help curb misuse.
- Search on topics that interest them and follow subject matter experts.
Employees should never:
- Offer financial advice to anyone on behalf of the financial institution.
- Act a representative of the financial institution (unless noted in the social media policy).
- Accept connection requests from people they don’t know.
- Post private information in a public setting. Take the conversation offline or use a private messaging feature.
- Overshare private information from their personal lives. Or, utilize list features to separate personal from professional.
- Share controversial content, such as political viewpoints, to colleagues or other professional connections.
- Use poor grammar and spelling; common abbreviations are acceptable, but writing out words in their entirety helps to eliminate confusion.
- Recycle or share content without crediting the original editor.
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Basic Info & Terminology For Each Social Channel
Sometimes it feels as though each social network has its own underground language. It’s not uncommon to get lost in a world of acronyms, abbreviations and seemingly nonsensical terminology when first starting out on a social network. To make matters worse, the same word could have two different meanings on different networks. In an effort to educate employees through this training program, it is helpful to provide definitions – or at least supplemental resources – that explain what each word or phrase means on each network. This will eliminate confusion and help employees understand policies without question.
Creating the training program is only step one. Make sure that all departments within your financial institution have read and agree to the program and the financial institution’s policies. All departments must be willing to enforce them when applicable. Be sure to consult each department before any final policies become active.
Developing an employee training program – and risk management policy – will ensure that your financial institution is taking the proper precautions for the safety and privacy of its customers and members on and off of banking hours.