Developing & Implementing A Social Media Policy

Developing and implementing a company social media and blogging policy requires consideration of a variety of factors.  In our forms section, we present three samples of different types of social media policies. One is a simple statement of general principles which by inference does not restrict employees but rather relies on their good sense and judgment. More precise but relatively less legalistic is another policy we offer which sets out a code of conduct but does so in general terms. Finally, we offer a formal social media and publicity policy. In selecting the policy which best suits your organization, we provide the following discussion of factors you should keep in mind.

First, determine the “culture’ that best suits your company situation.

Do you wish to promote a corporate culture of openness or do you wish to tightly control what your employees may communicate. In answering this, one crucial aspect is trust. Do you trust employees to communicate and develop relationships with customers? If not, be mindful that there are legal issues with reviewing blog posts if they are done on the employees own time and using their own equipment – these posts etc. are probably beyond any real company control. The better policy may be trust your employees to be good communicators and to use good judgment. This can go as far as not reviewing blog posts prior to posting.

Second, you need to consider whether you will offer training.

This is an real opportunity for management-employee communication which is always important. If you provide complete training about how to blog, you can include a review of legal issues with employees. We suggest you give employees an option of training rather than requiring them to participate.

Third, you will need to recognize that management will never be able to control all employee contacts with social media outlets.

It is just unrealistic to think otherwise. Therefore, at a minimum you should set out a policy requiring disclosure by bloggers of connections with customers, commercial or personal connections. Tell your employees that transparency and authenticity is key both for them and the Company. Tell them that they must clearly define if the blog, tweet etc. reflects the employee(s)’ opinion(s) or the company’s perspective.

Fourth, employees need to know that they must check their facts.

Much of what appears online is unsubstantiated or untrue. Inform your employees that before they publish any content (certainly things that will affect them), they must be certain that it is accurate and truthful. You should also inform employees that if they write about private conversations, they must ask for permission before publishing.

What about comments? There is no substitute for or avoiding the necessity of having an organizational “comment” policy. You will want to avoid having your company wind up in a lawsuit where the only reason the company is named as a defendant is that it had no policy restricting obviously wrongful employee public conduct issued from a company computer. Also employees will want to know what can land them in legal hot water. Set expectations and clearly communicate what is and what is not allowed on blogs, Facebook, Twitter etc.

In that regard, employees must be aware that they may be in a position to post negative and positive comments, but whatever they do they must not post inappropriate comments. They need to be told to make only statements that reflect their honest beliefs, opinions, or experiences, not to make deceptive or misleading claims, not to make unsupportable claims (meaning adequate proof exists to back up claims), not to engage defamation, not to  infringe on intellectual property, not to disturb privacy and publicity rights of others, not make offensive comments that could have the purpose or effect of creating an intimidating or hostile environment (like telling lies or spreading rumors on behalf of your company or in its name), not to use ethnic slurs, personal insults, obscenity, or other offensive language and not to make any comments or post any content that promotes unsafe activities that could lead to an unsafe situation.

If you have human resources and communications policies, you should have your social media policy refer to them. Also consider adopting an employee communications agreement to supplement your new policy which lists the things you wish to restrict. The agreement can include an acknowledgement of disciplinary consequences for inappropriate conduct. Remember employees often seek help and guidance when they are considering launching a blog. You will need to be ready to provide them the resources they want and need.

Assuming you decide to develop corporate blogging policies and guidelines, it may be very wise to include company bloggers in that process. They can help you think ahead in your social media policy development and ask them for help in extending the policy to other new and emerging communications technologies. If you have a legal department, also include them in the process. After you complete your policy, distribute it to all employees, companies that have facilitated wider distribution had their guidelines shared electronically.