A Social Networking Policy ?

This is the text of an invited talk I gave this evening at the Ireland France Chamber.   Joe Drumgoole also spoke on how to run your entire IT infrastructure as a start-up for less than US$2000 a year,  and Karlin Lillington on suggestions for how to best use social media tools for business.

What is the appropriate corporate policy for employees’ use of social media tools such as Facebook, Twitter and LinkedIn ?

I was CEO of a Nasdaq quoted company from 1997-2000 and then again from 2003-2006. Social networking media had yet to become mainstream, and at the time email and message boards dominated. I recall at the time I took the company public at its IPO in 1997, our US legal counsel gave us very strong advice about our communications policies – both what management could tell staff, and what staff could discuss with non-staff including their family and friends. This was quite a culture change across the whole company since up to that point we had been reasonably transparent about sales wins and indeed losses, and how the company was doing overall. At the monthly wine’n’cheese on the last friday afternoon of the month, I would literally stand on a chair, say a few words, and take Q&A from any of the staff on any aspect of our business. After going public, our legal counsel very strongly advised against such behaviour: management could only discuss the performance of the company with staff after appropriate disclosures to investors at large and only at certain times of each quarter. In addition, our staff were asked to sit through a video produced by the Securities Exchange Commission (SEC) which illustrated the perils – likely jail sentences and fines – of disclosing commercially sensitive information to people outside of the company, including family and friends.

We of course had a communications policy which emphasised to staff professional behaviour for the content and management of email, voice mails and other tools. We encouraged staff to be responsive on emails and on the phone: for example, never leaving the office at night with unanswered emails or pending voicemails. In fact, our use of electronic communication perhaps became too ubiqutous. I can recall that when we launched a particular new product, I deliberately positioned a relatively new member of our technical support team who would handle support enquiries arising from the new product, in our open plan offices very close to the senior engineer who had led the work on the new product. A few days after the launch, I wandered up the senior engineer and asked him how the customers were reacting to the launch. He answered that so far, things were going very well, and that in particular our technical support staff member was doing a really excellent job. I was delighted. But then the engineer said although he had frequent email exchanges with him, he had yet to meet the technical support engineer. I was astounded: I had deliberately changed the seating plan to bring the two together, but they had only ever communicated by email and never introduced themselves to each other!

By and large we had no particular difficulties arising from the occasional breach of our email policy. We did not attempt to monitor emails from our employees, nor the contents of phone conversations. Occasionally, like any large organisation, we would have a disgruntled employee and now and again, there would be an outgoing email which caused us a concern. This would be brought to our attention by the recipient, including sometimes a member of the press. Because of the nature of email as a medium, the identity of the sender was normally explicit and we could respond in an appropriate professional way, including following up with the staff member as appropriate.

On the other hand, we did from time to time have greater concerns about some staff postings to message boards. In particular, financial web sites such as Yahoo Finance typically have a message board allocated for each and every stock – including at the time, ours. In turn, postings to these message boards are frequently in effect anonymous: there may be a name given but it may not bear any relationship to the name of a specific individual. I am reasonably certain that from time to time, there were certain postings to these boards from just one or two employees, which were entirely inappropriate. Our concerns were generally higher than email cases, since there were potentially many many many more readers of a message board posting than a single email, and incorrect postings had the potential to damage the company and indeed even trigger SEC investigations into the circumstances and the people involved. Fortunately we had no serious incident, but the potential was always there.

Today, the industry has moved on, and not only do we have email, voice mail, blogs and message boards, but also Twitter, LinkedIn groups, Facebook pages and so on. It is entirely appropriate to consider what should be the correct corporate policy to adopt for staff members using these tools.

I think Twitter is particularly interesting to consider under this light. Because of its succintness, it fosters immediate submissions by contriibutors, rather than perhaps more thoughtful but lengthier postings in emails or blogs. It is one to many, including the possibility of fast re-tweeting of a message to yet many others. Once the send button is pressed, a tweet is gone: sure in theory you can request Twitter to remove a tweet, and they will, but the damage may already be done and not only may others have seen the offending tweet, they may have re-tweeted it on to yet others:  “What goes online,  stays online.”

There are some interesting cases to consider.  Taoiseach Brian Cowen’s on-air behaviour was famously tweeted by Fine Gael Cork South Central TD Simon Coveney.   Senator Dan Boyle has come under criticism for what others consider inappropriate use of Twitter, including Fianna Fail Limerick West TD John Cregan who has called Senator Boyle’s twittering “frustrating”. The Australian Speaker of the Lower House Harry Jenkins has reminded his fellow parlamentarians that tweets are not covered by parlimentary privilege. The President of the Dutch House of Representatives has expressed concerns about parliamentarians tweeting, and some Dutch observers apparently believe that parlimentarians overly concentrate on communicating to their local electorate than focussing on the complex issues relating to new legislation. What should be an appropriate policy for a political party to impose on its parliamentarians regarding social networking, and especially Twitter ?

Here in Ireland, we had a further interesting case when the well known TV personality Miriam O’Callaghan tweeted about the death of a colleague Gerry Ryan “Tragically it is true. So terribly shocking and sad. Life is just too cruel sometimes. RIP.” before the death had been officially announced and apparently before some members of his family were aware. She withdrew her tweet, but it was too late: it had already been picked up by TV3 for their 5.30pm news broadcast, amongst others. CNN fired a longstanding employee of 20 years, Octavia Nasr for her tweet “Sad to hear of the passing of Sayyed Mohammed Hussein Fadlallah … One of Hezbollah’s giants I respect a lot,” which apparently caused offence for some in Israel and the US. What should be an appropriate policy for a TV or radio station to impose on its staff especially on those staff very well known to the public, regarding social networking, and especially Twitter ?

We have further interesting cases. What should be the policy of say a newspaper regarding its journalists who may frequently tweet, especially when some of their tweets clearly relate to their profession as a journalist, and other tweets clearly are of a more personal nature and reflect personal views on an issue of the day ? What should be the policy of the Government, when it has external advisors participating in a consultative and advisory process and some of whom tweet about deliberations ? – for example, I personally tweeted reasonably frequently on the progress of the Innovation Taskforce earlier this year.

One possible policy response is to ban tweeting and other social media postings by your people. The social diarrhoea emissions must stop: they are outlawed. I personally believe that any attempt to stifle such emissions is counter-productive and I would strongly advise against it. It would otherwise create resentment, and a suspicion of opaque processes and hidden discussions.

Another possible policy is to request that your people have dual accounts on a particular social media tool: me as me, and me as employee of Acme Inc or as member of The Party. This in turn implies dual online identities – for example, two Twitter names. Personally I think such a schizophrenic policy is not very pragmatic and cumbersome for your people to adopt. Furthermore, external observers – such as Twitter followers – are likely to quickly know that your employee John Smith or your well known party member Dan ImportantMan or your well known journalist Miriam NotMarian has two online personalities, and will watch and correlate both.

Maybe a better policy is to request that all your people all use the same social media tool only for communications relating to your organisation, and use any other of their choice for their private lives. For example, only use LinkedIn, including LinkedIn groups, for all your job related communications but not for any other use; and use Twitter and/or Facebook and/or whatever you like for your personal communications and online social thoughts and comments. And never ever post job related communications to any of these other social media tools: only use LinkedIn. This policy is perhaps wiser than expecting your people to have two accounts on the same social media tool, but does not avoid external observers watching and correlating communications on different social tools from the same person.

Ultimately I believe the best policy is to stress professionalism and trust with your people. Gossip, inadvertent leaks, speculation and deliberate mistruths are a part of human social engagement during cocktail parties, overheard restaurant conversations, amongst red top journalists, and in many other places. Social media tools have not created the problem: they have just broadened the opportunity for discourse. Policies to control electronic communication may have some role to play, but the bigger picture is trusting your people to give considered professional communication, and to separate their professional work from the private social activities. Mis-informed commentary, in whatever form it takes, can damage a company’s reputation with customers, partners and the public. But more than that, it may bring personal liability for those who make such communications, up to and including fines and jail sentences from regulators such as the SEC. I believe that explaining the standard expected of your people, augmented with vignettes of both good and ill-considered behaviours, is your best policy.

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About chrisjhorn

https://chrisjhorn.wordpress.com/about/
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4 Responses to A Social Networking Policy ?

  1. Chris, thanks for putting up your presentation on a social networking policy. The evening was very informative, and agree with your emphasis on professionalism and trust. I will make sure everyone who attended is sent the link to this. Merci encore une fois! Cliona

  2. Gareth says:

    Thanks for a great article. I’m currently working down the split personality route and it is challenging.

  3. Pingback: Enterprise Ireland – Best Connected - Chris Horn on Corporate use of Social media –

  4. Christy Byrne says:

    I don’t agree that an appeal to professionalism is the best or wisest approach. Obviously, common sense applies and, certainly, appealing to professionalism has its merits. It is part of the solution, but putting such emphasis on it like this is naive and dangerous and leaves the organization open to damaged reputation and worse. Would you do the same for sexual or racial harassment policy?

    Instead, organisations must have a clear, documented, and enforced policy on social media use, along with guidelines on use, with examples. This policy could come from IT or the HR department, but certainly made part of any employment contract. Good governance is required for social media just like it is in other areas.

    Without a documented and enforced policy the organization is wide open to serious damage, and indeed legal attack even from a dismissed employee. The means to report abuse of the policy should be developed, and maintained. Examples of disciplinary action taken for policy violations should be included in the policy.

    Policy should define social media and lay down requirements for use – protecting IP, avoiding comment on business decisions in the offing, violating closed period requirements, and disclosing future features or acquisitions, commenting on current or pending legal action, avoiding offensive comment, adhering to the laws of libel and so on. So too must copyright entitlements of the company and third-parties.

    Employees must NOT be allowed post work-related comment anonymously. The must clearly identify themselves, their interests, including any financial holdings or stock interests and family or friend relationships IMO, and state that their views do not reflect company policy necessarily. If personal blogs touch on work-related aspects, however oblique, declarations to this effect must also be made.

    Finally, there should be a policy on how the organization’s resources are used for social media, so they enhance rather than degrade reputation and productivity.

    Your examples are great. That some of worst offenders in declaring interests when using social media, and behaving ethically and transparently, are in fact, Ireland’s journalists should, however, not come as a surprise to anyone at this stage. Try asking Vincent Browne about his nightly promotion of politico.ie on TV3.

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