Organizations are increasingly using social media internally and externally to communicate, educate, and market their products. But social media can be a “simultaneous blessing and curse,” according to a Nov. 26 Corporate Counsel article by Rebekah Mintzer. Many companies have successfully used it to expand their reach faster and further than possible by traditional means. But, it can also be a curse; a case in point is Twitter’s CFO’s recent public tweet about an acquisition target that he meant to send privately, Mintzer wrote.
Whichever the case, one thing is certain, says information governance (IG) consulting services firm Contoural Inc.: managing social media should be part of every organization’s IG governance strategy.
Tom Mighell, an attorney and senior consultant at Contoural, stressed that companies need to be able to account for their social media content just like any other electronically stored information. U.S. courts are including it in their interpretation of the Federal Rules of Civil Procedure. U.S. regulators also are actively regulating social media, as evidenced by guidelines from the Securities Exchange Commission for offerings and other securities-related communications and by the Financial Industry Regulatory Authority’s regulation of broker-dealers’ use of social media. The National Archives and Records Administration has instructed federal agencies to ensure that records are “identified, managed, and captured.” So, organizations definitely need a plan for governing their social media content.
Once organizations know where their social media content resides, they need to develop appropriate policies for capturing, retaining, and disposing of it, Mighell said.
“It’s pretty clear that the channels will not all have the same requirements for compliance,” said Mighell. External social media communications, for example, may have different compliance obligations than internal social media communications to employees. Therefore, Mighell said, companies need to understand what their social media channels are.
Next, organizations must do more than just communicate the policies to their employees. “We have seen so many companies that roll out policies with very little or no education, with no socialization, just an email—‘Here’s the new policy we have on records management, read it and follow it,’” said Mighell. This approach presents the rules without ensuring the employees fully understand what they mean, why they are important, and the consequences of not following them.
“The idea is to make a culture of compliance, where complying with that policy is second nature,” Mighell noted. “Where they understand the requirements, and it’s just a matter of course that they don’t even really think about it, but comply—they just do it.”
Though this may sound like a tall order, ARMA International has several resources that give practical advice on designing and implementing a reasonable policy for social media.
- “The Emerging Law of Social Media” (web seminar)
- “Implementing the Do’s and Don’ts of Social Media” (MER web seminar)
- “Managing the Social Media Information Explosion” (online course)
- Using Social Media in Organizations (ARMA TR 21-2012)
- Social Media Job Aid Bundle
- Hot Topic” “The Big Picture - Creating a Strategy for Organizational Use of Social Media” (free download)
These resources are available for purchase through the ARMA International online bookstore at www.arma.org/bookstore.