Even if your bank doesn't use social media, Regulators still say you're still responsible. What you need to know from Joanna Belbey~
Joanna Belbey I help regulated firms use social media effectively.
Opinions expressed by Forbes Contributors are their own.
There’s a misconception among banks that if they prohibit their employees from using social media, they can avoid the risks of damaging their brand or being out of compliance with regulatory requirements. The greatest risk is doing nothing to prepare for the crisis ahead.
The Stages (And Opportunities) Of Social Media
Regulated firms such as banks, typically ramp up the use of social media slowly. They may start with having a corporate presence that is closely aligned with their existing corporate brand, essentially moving their website to social. Or perhaps they may use social media as a way to make their firm more accessible for customer service or to show a more light hearted, personal tone. Or Human Resources might use social media for on-campus recruitment and to share positive stories about staff. During the next stage, firms may allow their employees to access social networks at work to make connections and do research, but use technology to block them from making comments or engaging. Or employees may be allowed to use social media for business and to communicate with clients and prospects but only if they agree to have their posts archived and share corporate-provided content that has been pre-approved in some way. From there, as time moves on, these employees may be allowed to post third party content and speak in their “authentic voice”, just as long there is technology and processes in place to capture these posts and make sure they are appropriate. Along the way, the C-Suite may recognize social media as an opportunity to build firm awareness, encourage engagement with employees and clients and enhance personal reputation. Or most recently, firms may encourage “employee advocacy”, where employees are provided with positive information about their firm and invited to share it on their personal networks. This is a powerful opportunity to promote the bank by trusted members of a community.
Regulators Say Your Bank Is Still Responsible, Even If You Don’t Use Social Media
However, in spite of the opportunities of using social media, there are plenty of banks that are still on the sidelines. However, whether or not you use social media as a marketing tool, a way to engage your community, or as an opportunity for your CEO, you still are responsible for the reputation of your bank. Even if your bank makes the decision not to use social media proactively and prohibits your employees from using it, there are still people talking about your bank on social media. People are having the conversation, whether you are there or not. It's better to be in the conversation to correct misconceptions, fix mistakes, or resolve customer service issues from a brand point of view. However, there is also a regulatory responsibility to protect the reputation of your bank and to protect your customers. The Federal Financial Institutions Examination Council (FFIEC), a consortium of retail banking regulators, states in its social media guidance that “based on its own risk assessment, a financial institution that has chosen not to use social media should still consider the potential for negative comments or complaints that may arise within the many social media platforms and when appropriate, evaluate what, if any, action it will take to monitor for such comments and/or respond to them”. And we’ve seen that regulators across industries tend to be consistent with the desire to protect consumers / investors / patients, so even if you aren’t a bank, the same principles will apply.
Create Social Media Policies For Everyone
Every bank should have social media policies that specifically lay out what’s allowed and what’s not allowed for their employees, by position. Marketing teams may have one set of rules and associated persons another. These polices are most effective when they use real-life examples that are relevant to employees and their families, spell out the consequences of not adhering to polices and are enforceable. Even when firms don’t use social media for business, firms still have a responsibility to train their employees to be sensible and aware. Nothing is private on social media. It’s easy to track down where you live or work. A misstep or controversial opinion from someone’s personal social media account can result in a social media firestorm that ultimately reflects negatively on your bank. Therefore banks need communications plans that include social media, whether they are using it or not.
Prepare For A Communications Crisis
In the early days of social media, people were more forgiving about mistakes and responsiveness. Not so today. The public expects that your bank will respond immediately during a crisis. That means you need to take steps today to prepare for the communications crisis that may happen at any time. Firms should gather together key stakeholders, such as Legal, Compliance, HR, Investor Relations, Marketing and Senior Management to explore and answer questions such as:
- How can we listen to what people are saying about our bank?
- What do we do when someone mentions our bank?
- How do we handle customer complaints?
- What is our process for correcting factual information (such as hours and locations) about our bank or branches?
- How do we protect our brand when it’s being hijacked on social media?
- What is our human resource process when an employee becomes the subject of a public controversy when using social media?
- What if a highly visible person, such as President Trump, tweets at us?
- How do we categorize and prioritize a crisis? Who does what in the event of a crisis?
- Who needs to authorize responses from the bank? What is their contact information?
Don't wait to figure out the answers to these questions while in the middle of a crisis. Plan ahead to create clear cut processes to protect the reputation of your bank now and in the future.
Contributor’s note: To learn more details about banking and social media, watch “Social Media and Compliance for Banks and Credit Unions,” a 45 minute conversation that I had with Andrew Swinney, social media manager for Kasasa, a wholesale financial services company.
Follow Joanna on Twitter @Belbey