CHAPTER 5

Social Media Policy and Guidelines: The Rules of Engagement

At this point, you should see social media as a business tool, not just a marketing channel. Social media will have a big impact on the way in which your business operates for the foreseeable future. Over 2 billion social media consumers cannot be wrong (Smith 2016)! So, your company has a decision to make—is it on or off the social media bus? We hope, given that you have made it all the way to Chapter 5, that you have jumped on board. But proceed with caution. For all the benefits of social word of mouth (sWOM), there can be negative consequences of embracing social.

In Chapter 4, we examined the Federal Trade Commission’s (FTC) Guidelines for Endorsements and Testimonials. We considered the growing practice of influencers, social consumers, and employees to endorse brands through social media and the potential legal issues that can arise from failing to adequately disclose when a material connection exists between the brand and the endorser. Unfortunately, this is not the only regulation that your company needs to have on its radar. As social media continues to be further integrated into our daily lives, in some cases, even replacing traditional methods of communication (e.g., telephone), the line between business and personal interactions continues to blur. Social media can increase a business’s liability exposure (Hamer 2013). For example, the National Labor Relations Act, Trade Secret Law, the Security Exchange Commission’s (SEC) Regulation on Fair Disclosure (Regulation RD), the Electronic Communications Privacy Act, The Copyright Act, and the Communications Decency Act, and much more apply to social media. Failure to comply with these Acts can result in legal action.

The first step to mitigating risk is to develop and implement a social media policy. In this chapter, we will examine the importance of having a well-developed social media policy, the process of creating a policy, and defining appropriate content. We will suggest some social media policies developed by other companies that may offer some guidance and inspiration. The goal of this chapter is to provide you with a framework for developing your policy. In the interest of full disclosure, we are not lawyers, and therefore, we recommend that when preparing your policy you consult your legal department. The framework presented here is offered as a general guide and may need to be modified to fit your company.

What Is a Social Media Policy and Why Do We Need One?

A social media policy is a code of conduct developed and approved by senior management. The purpose of a social media policy is to communicate how the company views social media, and how they will use it in a business context. Guidelines contained within the policy provide direction on how to use social media. These guidelines are often created based on a set of best practices. They protect the company, company employees, and their clients from public relations and legal crises and help the company present and maintain a positive and consistent brand identity. A well-written set of guidelines should also empower employees, providing them with the confidence they need to utilize social media effectively.

A typical policy will, at a minimum, include information on the social platforms the company has approved for business use, who is authorized to speak on behalf of the company, what content may or may not be posted, how to share content, and general rules of engagement.

For the most part, a social media policy is about educating employees to simply use common sense when using social media. But, as a wise person once said, common sense is not so common. A social media fiasco, where a company or an employee posts a cringe-worthy or litigious message on social media, is not that uncommon. As the following examples illustrate, many of these litigious actions were completed by employees who, in many instances, were not aware that what they were doing was wrong.

The probability of a company becoming embroiled in litigation or being on the receiving end of some bad publicity may in part be attributed to the manner in which the company manages their social media efforts. A company can either outsource their social media efforts to an agency with social media expertise or handle some, if not all, of their social media accounts in-house. A 2016 study of 511 businesses from a variety of industries revealed that approximately 57 percent of those surveyed managed all of their social advertising in-house (Keath 2016). Companies who outsource their social media believing their hired agency will be responsible for compliance may be mistaken and in for a rude awakening. The case of Sony and their advertising agency, Deutsch LA, which was covered in Chapter 4, is a living proof that even big agencies representing even bigger companies do not have it under control. Outsourcing the management of your official social media accounts does not absolve you of legal responsibility of company-related social media posts. Nor does it remove the need to educate all of your employees (even those outside of Marketing and Legal departments) on industry regulations and legal ramifications of using social media. The reality is that even if your official accounts are managed elsewhere, your employees are still using some form of social media (albeit personal), and may inadvertently post something inappropriate that can be associated with your company. They may not even be aware of how to appropriately engage with others on social media. A common misconception is that millennials, who were born into a digital world, have social media expertise. They do not. Millennials are technology-dependent, but not necessarily technology-savvy. They may be competent in using social media for personal use, but not for professional purposes. Therefore, a social media policy is necessary.

Having a social media policy is one thing, but understanding and applying it is something completely different. We are sure (or hope) that some of the companies mentioned in the previous examples had a social media policy in place. If they did, it is clear that one or more of the following happened: the policy was incomplete, the employees did not understand the policy, employees did not follow the policy, or social media postings were not monitored. If a detailed policy had been in place, if employees received training on the policy, and if someone had been monitoring online postings, there is a good chance that many of these transgressions could have been avoided. So let us discuss how to develop a social media policy.

Developing a Social Media Policy and Guidelines

Step 1: What Is Your Purpose?

The first step is to determine your purpose for using social media. Is social media to be used purely as a marketing communications tool—a tool to inform, persuade, and build relationships with existing and potential consumers—or does it serve a larger purpose? Do you want it be integrated into multiple functional areas (e.g., HR, purchasing, sales)? Are you striving to be a social business (see Chapter 3)? Clearly articulating your purpose for using social media is like planning a road trip. First, you decide where it is you want to go—why are you using social media? Then, you plan the best way of getting there and what resources and tools you will need (e.g., what platforms you will need, who will use them, what they need to know)? Without a clear purpose, you are likely to develop an ineffective policy. Common reasons for using social media in a business setting include, but are not limited to:

• Increasing brand awareness

• Strengthening the brand’s reputation

• Sharing and amplifying stories of success with external audiences

• Building and strengthening relationships with existing and prospective consumers

• Listening to and learning from consumers (i.e., marketing research)

• Engaging with vendors

• Improving customer service

• Increasing conversions (i.e., sales, lead generation)

• Recruiting and retaining high-quality employees

• Fostering pride among employees

It is likely that your company will have more than one purpose. Articulating your purpose and putting it down on paper will help you to identify appropriate social media platforms and content for your policy.

Step 2: Examine Your Company Culture

The next step, examining your company culture, begins by revisiting your company mission and values. Let these guide your policy-development process. Take, for instance, The Coca-Cola Company’s mission: “To refresh the world; To inspire moments of optimism and happiness; To create value and make a difference.” The Coca-Cola Company’s values include leadership, collaboration, integrity, accountability, passion, diversity, and quality (The Coca-Cola Company 2016a). Their social media policy, which is available on company’s website, embraces the corporate mission and values, encouraging employees to “Have fun, but be smart.” To “use sound judgment and common sense,” to “adhere to the Company’s values” (The Coca-Cola Company 2016b).

Next, consider the beliefs about social media that exist within your company. Do you have executive buy-in (see Chapter 3)? How do your employees feel about social media? What social media platforms do they use? The answers to these questions will help you to determine how detailed your policy will need to be, the amount of employee education and training required, and who you should invite to be a member of your social media advisory board.

Step 3: Create a Social Media Advisory Board—A Center of Excellence

A Social Media Advisory Board, or if you are looking for a name with little more pizzazz, a Social Media Center of Excellence, is a group of individuals whose purpose is to craft the social media policy and appropriate guidelines. Charlene Li, CEO and Principal Analyst at Altimeter Group, a research and strategic consulting company, contends that the Center of Excellence is a company’s moral compass. The Center collectively decides which platforms the company will use, creates policies on how to use these platforms, identifies best practices, and provides training for employees and any third party who may be posting on behalf of the company (e.g., social influencers), and ensures that the brand voice is appropriate and consistent (see Chapter 3) (Hootsuite University 2013). The Center should also sample social media posts within and across each of the company’s social media accounts to ensure that the content, language, and tone is consistent with the company’s brand personality and brand voice.

The size and composition of your company’s Center should be based on your purpose for using social media (Step 1). For instance, if you are only using social media for marketing purposes, the large majority of your Center will comprise of marketing employees. If you are a social business, then your Center should include representatives from all areas of your business (i.e., HR, Finance, Marketing, and so on). Even if your purpose is restricted to a particular business function, such as marketing, it is wise to have additional representation. An outsider may offer a different perspective, play “devil’s advocate,” and reduce the occurrence of groupthink. A Center may also include experts (industry and social media) as well as consumers. You may decide to include a member of your legal team to navigate potential legal landmines. However, it is important to remember that legal team is a participant in the process, not the sole driver. If you choose not to add a member of your legal team to your Center, you will still need them review your policy prior to implementation. Above all, when forming your Center, it is important to recruit “social-media-friendly” people. Seek out the “social media evangelists,” those individuals who see the value in social media and who will become internal advocates for the policy (Black 2010).

During the early stages of policy development, the Center may need to meet on a regular basis. Once the policy has been developed and employees trained, meetings may be less frequent. The work undertaken by the Center will also evolve over time. When the policy is first introduced, the Center may work as a centralized body, vetting planned social media activities and monitoring online activities. As the workforce becomes more skilled, the approval and monitoring process may become decentralized. The Center may only need to meet a few times a year to review and update policies. We recommend meeting at least twice a year.

Step 4: Research

Once the Center of Excellence has been formed, the next step is to conduct research. The research phase involves reviewing existing business policies, researching best practices, identifying potential laws and regulations, and benchmarking against other companies. It is advisable to create a centralized system for posting and sharing information collected. An internal website, Google Documents, or Dropbox folder are all suitable options.

Review Existing Policies

The first step is to determine if there are existing policies in place that address the use of social media in the workplace for business or personal purposes (e.g., HR policies). If policies exist, the Center needs to decide whether the existing policies can be amended or whether new policies are required. As social media is integrated into multiple functional areas; it is likely that existing policies will need to be updated. For example, if a business decides to use social media as a recruiting tool, current human resources policies are likely to be impacted and will need to be updated. The new social media policy crafted by the Center may reference the use of social media for recruiting; however, the recruiting policies that reside in HR may be silent on social media or offer conflicting guidelines. For this reason, it is advisable to review all existing policies to determine those that need to be updated so as to avoid conflicting policies.

Best Practices

Social media platforms are constantly in a state of flux. Platforms such as Facebook frequently update their interface and newsfeed algorithms to enhance user experience (and maximize revenue). The manner and purpose behind consumers’ use of social media also changes over time. Two years ago would you have considered ordering pizza via Twitter? Probably not. However, today Domino’s Pizza offers a “Tweet to Order” system for their consumers. This illustrative example highlights a social media truth: social media is a moving target. As such, some best practices will change over time.

Best practices can be categorized into two areas: rules of engagement and platform approach. Rules of engagement are appropriate behaviors for social posting and engaging with consumers on social media. The mission and values of the business will guide the creation of these approved behaviors, as will the rules of professional communication etiquette. To illustrate, some of Best Buy’s values are respect, humility, and integrity (Best Buy 2016). Best Buy’s social media policy and guidelines call on employees to be smart, respectful, and human. Employees are required to disclose their affiliation with Best Buy, act responsibility and ethically, and to honor differences (Best Buy 2014). Rules of engagement can also be formulated from a variety of external sources including industry and consumer expectations, published research, social media experts, professional and industry organizations (e.g., WOMMA.org), and societal expectations. See the Appendix of this book for some valuable resources.

Platform approach refers to appropriate methods of communicating and engagement on specific social media platforms. Approaches to using specific platforms can be general (what type of content can be posted on which platform) or specific (the best days of the week and times of the day to post). Similar to rules of engagement, these approaches are formulated from a variety of sources, including an analysis of those activities that generate the greatest level of engagement of the company’s account (views, positive comments, likes, shares, downloads, and so on) and published research reports (academic, industry, and organizational). Please note, companies often publish an abridged version of their social policy and guidelines on the company website. It is unlikely that this public version of the policy will include how the company will approach each platform. A more detailed document containing guidelines for how employees should use specific platforms may exist offline.

Laws and Regulations

Federal and state laws, as well as industry regulations, may apply to social media. The majority of these fall into three categories: intellectual property, employment-related issues, and marketing activities. A policy will, at a minimum, provide a statement requiring that employees comply with government laws and industry regulations. A list of these laws and regulations is often included. A more robust policy will include details of or links to a detailed description of each law and regulation, with instructions and guidelines to ensure compliance. The closer a company moves toward being a social business, the greater the number of laws and regulations to which the company, their employees, and third parties must comply. The Social Media Center of Excellence should seek legal advice on laws and regulations that apply to their industry and social media activities. See the Appendix of this book for a link to some industry resources.

Your company is also bound to the terms of service for each social media platform (Facebook, Twitter, and so on) that you use. As such, platform-specific terms of service and policies should be reviewed in advance to identify any potential obstacles (Smith, Gambrell, and Russell 2016).

Benchmarking

The task of developing a social media policy and guidelines can, at first, appear overwhelming. But there is no need to reinvent the wheel. There are many examples of comprehensive, well-written social media policies available online. Begin by contacting industry associations for sample policies and guidelines. Next, research competitors to identify the breadth and depth of their social policies and guidelines. Finally, it may be helpful to review the policies of leading corporations, such as IBM, Microsoft, The Coca-Cola Company, Intel, and Adidas, which are available on each company’s website. Keep in mind, the policies and guidelines available online may be an abridged version. If you are still looking for more examples, the Social Media Governance Website (http://socialmediagovernance.com/policies/) maintains a database of over 100 social media policies (Black 2010).

Step 5: Draft a Document and Distribute for Feedback

Drafting a policy is like writing a book. It takes time and multiple drafts to get it right. The first draft may be quite lengthy. Do not worry, remember, it is easier to reduce the size of a document than it is to add to it later. Keep the document simple. Use simple, easy-to-understand language. To reduce the need for frequent updates, try to avoid including information that may outdate quickly. Keep lengthy paragraphs to a minimum and use bullet points to emphasize key points. A draft of the policy should be submitted to your company’s attorney and senior management for feedback and final approval. If the final document is large, consider developing an abridged version for easy daily reference.

The Social Media Policy: What to Include

The following is a brief overview of each section in a typical social media policy.

Policy Statement

Begin by stating the policy. In your policy statement, you should include whom the policy applies to (scope) and the reason for the policy (purpose). If appropriate, you can link the policy to the company’s mission and values.

Approved Platforms

This section will list the social media platforms that the company has approved for official business purposes. These terms of services and policies of each platform should be vetted by the legal department before adoption.

Account Status

There are two categories of accounts, official accounts and unofficial accounts. Official accounts are those accounts approved, created, and managed by the company. A list of and links to all official accounts should be included in the policy document.

Unofficial accounts are created by employees, individual departments, and consumers. These accounts may include your company name or logo, but were not vetted by the company, and the content that is being posted to these accounts is not being monitored. To the average consumer, these unofficial accounts may look like authorized accounts. For that reason, your company needs to decide the manner in which they handle these accounts. The policy document should clearly state how the company will address unofficial accounts.

There are three options for managing unofficial accounts.

• Independence: Allow the account to exist and independently operate. You should carefully consider this option. By allowing these accounts to operate independently, your company has little to no control over the content. This could have negative implications for your company.

• Compliance: Contact the account holder and encourage him or her to apply for official account status. In this case, the company will allow the account to remain as long as the account administrator abides by the company’s social media guidelines. In return, the company may offer to list the page on the company website and will grant the account administrator permission to use company images and logos. Transitioning an unofficial account to become an official account may be a viable option if the account has a large following and has achieved positive results. Someone within the company will need to be responsible for monitoring the account to ensure continued compliance with company guidelines. If the account holder declines your offer to make their account official or does not respond to your request, you may decide to move to option three—termination.

• Termination: Contact the account administrator and request that he or she remove all company intellectual property (logos, trademarks, and so on). Also, request that they must clearly indicate on the account (in the bio or account description) that this is an unofficial account, and that all posts are made by a specific individual (and include his name). If the account holder fails to comply, you may want to issue a cease and desist letter. You should also file an unauthorized trademark use report with the specific platform.

Legal Issues

The policy document should, at a minimum, include a statement requiring that employees comply with federal and state laws and industry regulations. A list of these laws and regulations should be included. An additional step is to include details of or links to detailed descriptions of each law and regulation along with instructions and guidelines to ensure compliance.

Account Access

The policy document should indicate who is permitted to post on behalf of the company. If employees are required to complete training before being granted permission to post, then this should also be stated.

Account Ownership

There may be instances in which an employee creates a social media account that is granted “official account” status, yet the account was created with the employee’s work e-mail address (e.g., janedoe@socialgurus. com), rather than using an administrative e-mail address (e.g., social@ socialgurus.com). Common sense would dictate that once the account receives an official status that the e-mail address associated with the account would be updated. If this slips through the cracks, it may be worthwhile to include a statement that states that all accounts that have been granted official status are the property of the company. That way, if an employee leaves the company, the account ownership (login) will transfer to the company.

Brand Voice

In Chapter 3, we discussed the importance of humanizing your brand. To convey this personality, you need to develop a brand voice. Brand voice is how that personality is portrayed through communications. Creating a brand voice begins by reviewing the mission of your company to help you identify the appropriate language and tone to use in your social communications. Regarding language choice, you need to decide whether you want your posts to be written using simple or complex words, should the message be serious or fun, and should you include or avoid the use of technical jargon. Another factor related to language choice is the need to establish a consistent message tone. What is the appropriate tone that reflects your brand personality? Is it direct, personal, scientific, fun, sassy, humble, and so on? Communication is certainly not just about word choices. You must also consider the appropriate type of photographs and video. Visual components of the message must be aligned with the brand voice and accurately reflect the brand’s personality. In Chapter 3, we offered the example of Taco Bell. Taco Bell’s brand voice is humorous and wacky. The Taco Bell Facebook page recently contained a post titled “This just happened: I got engaged to a Doritos Locos Tacos.” Accompanying the announcement was a picture of high school student dressed in a suit proposing to a taco. On Twitter, the company posts visuals, which include funny taco gifs, and pictures of taco t-shirts, all of which support the company’s brand voice. In the same chapter, we described Adidas’s brand as inspirational. During the 2016 Summer Olympics, the Adidas Facebook page included a number of posts that included photographs of inspiring paralympians. Developing guidelines that include appropriate language, tone, and content is important to ensure that all employees and third parties posting on behalf of the company are all using the same voice.

Best Practices: Rules of Engagement

When educating employees on how to engage with followers on social media, it helps if you include both specific directions and examples. Following are some suggested, although generic, guidelines that companies may adopt. Please note that depending on the expectations of your industry, your company and the laws and regulations that apply a company may decide to elaborate on each item.

Best Practices: Platform Approach

People are motivated to use different social media outlets for different purposes. For example, Facebook is popular for communicating with family and friends, whereas LinkedIn is more appropriate for communicating with company and industry associates. Furthermore, each platform has its nuances that will impact how information is shared. If your company decides to restrict specific communications to particular platforms or has a preference for how that information is presented, then this should be outlined for employees. Platform approach guidelines may be appropriate when a large percentage of the workforce is permitted to post to and engage with consumers on social media. Walmart is an example of a company that offers separate guidelines for Facebook and for Twitter (Wal-Mart Stores 2016).

Policy Enforcement

In addition to providing rules of engagement, it is also important to explain to employees the consequences of failing to adhere to the policy or follow the guidelines. The severity of the punishment will largely depend on the infraction, ranging from a warning to termination. It is up to your company to decide on the appropriate punishment for a specific infraction. Your human resources and legal department can assist in crafting a statement for inclusion in the document.

Introducing the Policy

Once the policy has been approved by the legal department and senior management, it is ready to be presented to employees and relevant third parties. The manner in which the policy is introduced to the workforce is a function of the size and culture of the company, geographic disbursement of employees, and how social-media-savvy your employees are. The obvious place to introduce the policy and guidelines is during new employee orientation. For existing employees, an alternative strategy will be required. For a small business, a short in-person information and training session may be sufficient. For larger organizations with a more disbursed workforce, a more creative approach may be required. One suggestion is to create a short educational video. The global auditing company KPMG created a four-minute video to explain their social media policies and guidelines (Tung 2014). Another alternative is to offer training through a series of webinars.

Whereas a four-minute video or a brief in-person information session may be sufficient for providing a general overview of the policy and guidelines, a lengthier, more detailed training session may be required for those employees authorized to post on behalf of the company. As an example, the computer and technology company Dell requires employees to undergo a certification process before being granted permission to post on behalf of the company. Dell created their own Social Media and Communications University (SMaC U—pronounced “smack you”) to train Dell employees on the best way to use social media. The certification process includes the completion of three mandatory classes and one class on a specific social media platform. The mandatory classes include, SMaC Principles—a class that covers Dell’s five core principles for proper engagement; Getting Started SMaCing—a class where employees learn how to engage in social media and the social media tactics and tools that are at their disposal—Building Brand on SMaC class where employees learn how to support the Dell brand through content, voice, and actions. Platform-specific classes are offered for Facebook, Twitter, Community, LinkedIn, and Google+. Upon successful completion of the certification program, employees are permitted to speak on social media on behalf of the company. The certification program, which takes approximately eight hours to complete, has reduced the company’s need to monitor social media communications (Deshpande and Norris 2014). As of July 2015, over 15,000 Dell employees were SMaC U-certified (Petrone 2015).

Regardless of the method of delivery—in-person, webinar, or video—the best way to develop an informed and skilled social media workforce is not just to tell them what to do, but to show them how to do it. Employees should, in a controlled environment, be given the opportunity to put it into practice what they have learned. A sound training session will use stories and examples to help employees understand the rules. It will also present them with some common scenarios to which they are asked to apply the guidelines they have learned.

Periodic Review

The final step of the process is to periodically review both the policy and guidelines to ensure that they are current. It is also important to revisit the legal aspects of social media. As updates are made, refresher training for all employees will be required. Even if there have been no changes to the policy or guidelines, it is advisable to offer a brief refresher training, perhaps once a year. A short video may be an effective approach.

Social Media Policy Examples

As stated earlier, there are many great examples of social media policies available online (simply search using the company name and the words “social media policy”). You may want to consider reviewing some of these for inspiration. Keep in mind that some of these policies may be the abridged version of a larger policy that is accessible only to company employees. The following discussion summarizes a few examples of policies that are worth reviewing. Links to access these social media policies and others are located in the next section and in the Appendix.

Now that we have provided the framework for establishing a social business, outlined the legal issues surrounding social word of mouth (sWOM), and offered suggestions on how to create a policy, the remainder of the book will guide you on how to create a shareworthy persuasive message for a variety of popular platforms.

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