Acceptable Use: Managing Your Company’s Social Media Policy

Can you really “manage” your employees’ use of social media? And is a policy even worth the email it was distributed on?

There are some (questionable) estimates that “social activity” on the web has eclipsed email, measured in terms of time/day spent on that activity. But as with email, the social time for any one individual is fractured across a huge array of attention-seekers. Friends, families, scads and scads of marketers – the opportunity to serendipitously insert oneself into the stream of another individuals daily online life is slim, fleeting, and fraught with risk.

It is no wonder then that some companies tread warily into the social space. The waters are deep (there are 1000’s of channels – and more every day – through which a social media strategy could be executed) and the current swift (Facebook is not nearly the most popular social media platform on mobile devices), but there are legitimate questions about what a financial services company can, and cannot, say in those environments.

This week’s ArcherShots takes a look at acceptable use policies, and how social forces you to turn your company culture inside out.

If you’ve got 20 seconds

  • Social media turns your company culture inside out: If your culture doesn’t reflect well on your company, social media policies can’t help.
  • Laying down rules or laying down cover? Decide if your policy is mean to guide employees, or protect the company. It can’t do both.
  • Enforcement: except for clearly illegal/unethical behavior, most attempts to clamp down will fail. Engage instead.

In Depth (If you’ve got 10 minutes)

Culture Code: What Unified Voice?
It is a high conceit of many corporate PR departments to believe that an organization’s voice, tone and style can be determined from a central point, and directed outwards from within. As in any complex human endeavor, the collective voice can at times be swayed in one direction or another, but is made up of many individual (though interconnected) pieces. Each has its own motivations, goals, and influences. Some have a particularly self-serving loyalty to the company, while for others the association is fleeting.

All of them are potential spokespeople, with the universal availability of Twitter, Facebook, Foursquare, and LinkedIn (among others.)

The only voice that that can penetrate this cacophony of conversations is one offering the speakers some incentive to align with the company. “Tweeter,” you may say, “promote thyself.”

Social media turns your company inside-out: whereas before you had the luxury of devising a communications strategy and rolling out according your media plan, pivoting when circumstances dictated, now you may find yourself constantly on the defensive. This is problematic enough when the barbs are coming from disappointed customers; it is a much larger problem when it comes from within.

For better or worse, your company’s culture is turned inside-out with employee’s social media usage. As you ask, “what message do we want to communicate to our customers, our market,” you must first answer, “what message do we tell ourselves?”

Laying the Ground Rules: Social Media Acceptable Use Policies – Land of the Specifically Vague

Let’s begin in that refuge of the first resort – the competitive landscape. It’s likely to be somewhat helpful to at least look at what other organizations, across the spectrum, are doing to lay out the ground rules for social media engagement. A comprehensive collection of Acceptable Use Policies can be found here, but many companies’ guidelines boil down to a few essential points:

  • Be nice
  • Be discrete
  • Before you post, ask: “Would my grandmother approve?” (Unless your grandmother is Betty White.)

There acres of uncertainty in these policies, mostly as a result of a Social Media Use committee or other group attempting to cover all possible ground, even the ground they don’t know exists.

And it can’t be any other way with social media: the landscape evolves too quickly for a committee to react to each new change. What impact, for example, does Facebook’s new Open Social data sharing policies have on employees of companies who are asked not to endorse or comment on content which appears on third party news websites? (Such employees, if they don’t specifically disable Facebook’s new settings, might find their commentary or endorsement – shared only on Facebook – syndicated out to one of the hundreds of sites running Facebook’s Open Social platform.)

Warren Buffet has said, “don’t do anything you wouldn’t want to read about in the paper the next morning.” That seems to be the undertone of most of these policies. But if the policy basically comes down to “use your best judgment”, you’re obliged to ask yourself: do you trust your employee’s judgment?

In an age of pervasive social media, we are all marketers – even if reluctantly so. So, can you trust everyone’s judgment? If the answer isn’t “yes”, then your problem is not one which a social media policy can solve.

How to Craft an Effective Social Media Policy

Ask first if the purpose of the policy is to provide guidance to employees who want to participate fully in the social ecosphere, or to provide direction to HR in dispensing disciplinary action. This is not a cynical choice: committing to the acceptable use of social media among employees requires you to be honest and forthcoming about what is clearly out of bounds, and then to accept graciously any activity which falls into a gray area as the inevitable outcome.

The alternative – the middle path, so to speak – is an Acceptable Use Policy numbering in the 100s of pages which few people read and fewer understand, paired with arbitrary enforcement of disciplinary action that the whims of line managers, and an inevitable explosion of negative sentiment seeping out onto Facebook and Twitter for all of your customers, partners and regulators to see.

Where clear lines can be drawn, draw them. Where there is wiggle room, understand that you are dealing with human behavior, and learn to accept the varieties thereof.

Legal Constraints

Outline what is clearly off-limits: for example, discussing customer’s personal financial information on a social channel, even one which is “private”, should be outright forbidden. Marketing and communication departments probably don’t have to lead the way on this, as IT is probably there already. But help employees know how to a) comply with this requirement, and b) move the conversation to an appropriate medium when necessary.

Think, too, about what is not necessarily off-limits, but highly regulated. For example, there are some very specific rules about when a “mass” social communication becomes a sales pitch, for FINRA industry professionals. Here the approach is to take an existing framework of acceptable behavior, and fit various forms of electronic interaction into the pre-existing definitions provided in that framework. Such an approach has the benefit of using a language with which members are familiar, but may find certain subtleties to be problematic. (Does my twitter feed become sales literature when I receive my 25th follower? If the website to which I link is considered an advertisement, is the Facebook wallpost as well?)

Finally, identify areas of specific liability, and communicate that to your employees who are social network users. For example, “discussing non-public information on a social network, even with a fellow employee who is already privy to that information through other channels, has the potential to be inadvertently disclosed to outside entities. Such action might be considered ‘selective disclosure’ under Regulation FD, and subject the company to possible enforcement action.” It is critical to communicate not just what, but why.


It bears repating: social networks turn company culture inside out. The nature and tone of that culture will have a far larger effect on what your employees express, and how they choose to express it, than any social media policy. If you find yourself attempting to catalog all of the “don’ts” of acceptable use, that’s a fairly good sign that the natural openness and free-flowing structure of the social web is not going to mesh well with our culture.

At that point, you have a choice to make: change your company’s cultural habits and moors, or prepare to spend the bulk of your time enforcing a “no fly” policy across a vast array of social networks. (If you decide on the latter, we owe you this warning: it is not likely to work for very long, and you’ll eventually be forced to address the cultural issues head-on, and probably under a considerably larger degree of stress.)

Should you decide that your company can benefit from an attitude of open expression, free-flowing ideas, employee opinions that conflict with the stated company position, there are a variety of steps you can take to help foster this atmosphere and help it to work in your favor. First, a helpful little formula:

Customer -> The Employee -> Culture -> Policy

Lead by example. A few corporations (Apple, Berkshire Hathaway, Virgin) are cults of personality. For those that are, their CEO’s don’t need a social media presence: the mainstream media will provide ample exposure.

For the rest of us, there surest way to demonstrate that we support open and honest communication, diversity of opinion, a dedication to our customers and clients, and a belief in the power of social media to break down walls between us and those we serve, is to get out there and start doing it. Answer a customer’s question. Address a complaint. Suggest that someone check out what you’re selling (and hey, why not suggest a competitor’s offering as well. See if that doesn’t build credibility.)


Inevitably, there will be instances where someone steps over the line. Assuming these aren’t outright breaches of security or confidentiality, or harassment but rather breaches of decorum, you have a number of choices in determining how to respond:

  • Do nothing
    Often the most effective, and certainly the cheapest and quickest option.Determine if you have a legal/ethical/moral obligation to act. Has the employee merely departed (even wildly) from the official position of the company?
  • Intervene, offline
    Also effective, and quite easy to implement. Perhaps an employee has expressed ardent support for a public policy which runs counter to the company’s interest. Here it may simply be effective to suggest, in conversation, that said employee clearly delineate her positions from those officially supported by the company.
  • Join the conversation
    Paradoxically, this involves the most gray area, because depending on the topic you could be seen as pushing a corporate line, taking sides, or harassing an opposing viewpoint with the “weight” of your position. But if you approach the conversation with humility and genuine interest in understanding another viewpoint, you win credibility and support the robust growth of your social strategy.

Coming soon: options for dealing with the workeffort associated with supporting widespread social media use; tools for listening/monitoring; Facebook’s coming doom.

Leave a Reply

Close Modal

Contact Archer

Close Modal

We know you're still using an older version of Internet Explorer. Do you know how much mind-blowing stuff you're missing because of this?

Save yourself. Upgrade now.
We'll help you...