BANK SOCIAL MEDIA POLICY
Bank recognizes the importance of the Internet in the day-to-day operations of the Bank. From marketing to reputation management to recruitment of new employees, the Internet plays in major role in the Bank’s overall strategy. And now, the Internet is generally synonymous with social media and its popular social networks such as Facebook and LinkedIn. Use of Facebook, LinkedIn, blogging, wikis and other online social media vehicles are commonplace.
This policy is intended to assist employees in making appropriate decisions about work-related blogging social media interaction. This policy must be used in conjunction with other tools provided to employees, including the Acceptable Use Policy, Employee Guide to Information Security, Human Resources Guide to Social Media Risks, and related training.
The lines between work and personal life can become blurred. In general, what you do on your own time is a personal decision. However, activities in or outside of work that affect your job performance, the performance of others, or Bank business interests are a proper focus for Bank policy.
WHAT THE BANK EXPECTS TO GAIN FROM SOCIAL MEDIA
As a community bank, Bank recognizes the importance of our employees joining in and helping to shape conversations regarding the Bank and the communities we serve. Bank is committed to supporting employees desire to interact knowledgeably and socially on the Internet through social media.
Contributing to the online conversations about banking or our communities means being present where and when they are taking place. As technology tools enable an easy exchange with community members, governmental representatives, clients, and the public, we encourage employees to share the insights and expertise gained through work at Bank. This can be done without first asking permission provided this guidance is read and followed.
“TARGET” OF THE BANK’S SOCIAL MEDIA EFFORTS
The Bank’s social media efforts are targeted at several stakeholders:
1. Existing Customers: To provide existing customers with information and conversation/engagement opportunities relative to ongoing activities at the Bank and in the community. Ultimately, the goal is to convert a “customer” into an “evangelist” for the Bank.
2. New Customers: To create sufficient awareness in the local marketplace that results in new customer originations – deposit, lending, and other services. The marketplace is full of competitors with similar “commodity” products and services. Social media allows the Bank to “humanize” itself and set itself apart from the competition.
3. Media: Social media provides the Bank with a platform to communicate with the media regarding its ongoing activities and rich history. Through social media the Bank can embed video and other media that can assist the media when developing content. For example, a bank video can be reposted and potentially result in viral distribution.
4. Regulatory Agencies: Social media provides a channel through which the Bank can highlight compliance with regulatory requirements. For example, social media allows the Bank to easily demonstrate its compliance with the Community Reinvestment Act. Further, social media provides a convenient mechanism through which to receive consumer complaints or positive feedback.
5. Community At-Large: Social media introduces Bank to the community at-large. The content created on social media provides an information distribution channel through which interested parties can learn about Bank.
Being able to share your and the Bank’s activities without prior management approval means the Bank trusts you to understand that by doing so you are accepting a higher level of risk for greater rewards. Each Bank employee is personally responsible for the content he or she publishes on any form of social media. Be thoughtful about how you present yourself in online social networks.
You may have identified yourself as a Bank staff member or the Bank as your employer, either directly or as part of a user profile. If so, ensure your profile and related content is consistent with how you wish to present yourself to the Bank’s stakeholders, your business contacts, and your colleagues and peers.
Senior management have special responsibility with their Internet presence by virtue of their high profile position within the Bank, even if they do not explicitly identify themselves as being affiliated with the Bank. Such senior level staff should assume that his or her posts will be seen and read by Bank stakeholders and that they will presumptively associate such posts with the Bank.
Trust is an essential ingredient in the constructive culture we are striving to achieve at the Bank. We can’t be there to guide every interaction, so we expect you to follow these guidelines and advice to help you better balance the risk vs. reward ratio.
SOCIAL MEDIA OVERSIGHT
The Social Media Manager is responsible for managing the Bank’s social media strategy. The Social Media Manager, or an assignee, will provide training and monitor activity on an ongoing basis. Inquiries regarding the Bank’s social media strategy must be forwarded to the Bank’s Social Media Manager.
The Social Media Manager is responsible for determining “community managers.” Community managers are employees and third parties that are provided with authority to act as administrators on the Bank’s behalf. The Social Media Manager must select individuals as community managers that possess the requisite technical skills as well as understand the risks associated with social media. All community managers report directly to the Social Media Manager relative to matters related to social media – regardless of their role within the Bank.
These guidelines will help you open up a respectful, knowledgeable interaction with people on the Internet. They also protect the privacy, confidentiality, and interests of the Bank and its customers. Note that these policies and guidelines apply only to work-related sites and issues and are not meant to infringe upon your personal interaction or commentary online. Regardless, all employees must determine the potential impact that “personal” interactions may have upon the Bank and its customers, vendors, and other stakeholders. Ultimately, employees are held accountable for ensuring that interaction is appropriate and consistent with this policy and other Bank guidance.
· The goal is to ensure the Bank’s voice is part of the larger conversation relating to community banking and the communities the Bank serves. Do not embark before understanding the conversation. First, explore the topic being discussed, read about it and contribute only when input adds or advances the discussion. Include an especially relevant link, since doing so further connects the Bank to the wider Web and can result in greater connectivity for the Bank.
· Keep in mind that posts are visible by all with online access. It may be fine to share your work at the Bank as part of your participation in the online community, etc., but you DO NOT have permission to reveal any information that compromises Bank policy or public positions. By that we mean don’t share anything that is proprietary and/or confidential to the Bank. For example, it is not okay to share any content that required a non-disclosure agreement or is part of a confidential management or Board discussion. Other items that may not be disclosed include any customer and vendor information that is not publicly available.
· If you are developing a Web site or writing a blog or making any other social media comment that will mention Bank and/or our current and potential products, employees, partners, customers, and competitors, identify that you are an employee of Bank and that the views expressed on the blog or Web site are yours alone and do not represent the views of Bank.
· Unless given permission by your manager, you are not authorized to speak on behalf of the Bank, nor to represent that you do so.
· If you are developing a site or writing a blog or making any other social media comment that will mention our company and / or our current and potential products, employees, partners, customers, and competitors, as a courtesy to the company, please let your manager know that you are writing them. Your manager may choose to visit from time to time to understand your point of view.
· You may not share information that is confidential and proprietary about the Bank or its customers. This includes information about upcoming product releases, sales, finances, number of products sold, number of employees, Bank strategy, and any other information that has not been publicly released by the company. These are given as examples only and do not cover the range of what the Bank considers confidential and proprietary. If you have any question about whether information has been released publicly or doubts of any kind, speak with your manager before releasing information that could potentially harm the Bank, or our current and potential products, employees, partners, and customers. Before embarking on any such endeavor employees should be familiar with the Bank’s other applicable policies, including the Acceptable Use Policy, Employee Guide to Information Security, etc.
· Bank logo and trademarks may not be used without explicit permission in writing from the Bank. This is to prevent the appearance that you speak for or represent the company officially.
· Speak respectfully about the Bank and our current and potential employees, customers, partners, and competitors. Do not engage in name calling or behavior that will reflect negatively on the Bank's reputation. Note that the use of copyrighted materials, unfounded or derogatory statements, or misrepresentation is not viewed favorably by the Bank and can result in disciplinary action up to and including employment termination.
· The Bank encourages you to write knowledgeably, accurately, and using appropriate professionalism. Despite disclaimers, your Web interaction can result in members of the public forming opinions about the Bank and its employees, partners, and products.
· Honor the privacy rights of our current employees by seeking their permission before writing about or displaying internal company happenings that might be considered to be a breach of their privacy and confidentiality.
· You may not sell any product or service that would compete with any of the Bank's products or services without permission in writing from the Chief Administrative Officer. This includes, but is not limited to training, books, products, and freelance writing. If in doubt, talk with your manager or the Chief Administrative Officer.
· Recognize that you are legally liable for anything you write or present online. Employees can be disciplined by the Bank for commentary, content, or images that are defamatory, pornographic, proprietary, harassing, libelous, or that can create a hostile work environment. You can also be sued by Bank employees, competitors, and any individual or company that views your commentary, content, or images as defamatory, pornographic, proprietary, harassing, libelous or creating a hostile work environment.
· Media contacts about the Bank and our current and potential products, employees, partners, customers, and competitors should be referred for coordination and guidance to the Chief Administrative Officer. This does not specifically include your opinions, writing, and interviews on topics aside from the Bank and our current and potential products, employees, partners, customers, and competitors.
· Make sure that your online activities do not interfere with your job performance.
· Respecting differences, appreciating the diversity of opinions and speaking or conducting yourself in a professional manner is expected at all times. If you aren’t completely confident about what you intend to share, you should seek management input before you post.
HOW WILL SOCIAL MEDIA BE IMPLEMENTED AT THE BANK
The Social Media Manager of the Bank is accountable for determining the Bank’s Social Media Strategy. The Bank’s use of social media is largely to develop a “community” of Bank supporters and to raise awareness of the Bank’s brand. This is largely done through interaction on mainstream social media platforms such as Facebook, LinkedIn, Blogger, and Twitter. The specific platforms used may change from time to time as technology evolves and audiences shift. Regardless, the guidelines above remain in effect. Questions regarding the Bank’s use of social media should be directed to the Social Media Manager.
TYPES OF BANK ACTIVITIES/POSTINGS
The primary purpose of the Bank’s social media activities is “community building.” While the Bank will from time-to-time promote products and services, the primary focus is the creation of an online community where the Bank can share its history and mission and where stakeholders can maintain conversations with the Bank. The Bank does not “censor” comments made by third parties and only removes comments if they are considered obscene, pornographic or similarly inappropriate. As such, it is the Bank’s policy to remain transparent and not delete derogatory comments. Instead, it is the Bank’s policy to attempt to understand the origin of any derogatory comment in an attempt to “correct” any error or misunderstanding caused by the Bank. Management is responsible for monitoring content on an ongoing basis (generally daily).
The Social Media Manager is responsible for determining “community managers” given authority to post on behalf of the Bank. The Social Media Manager is responsible for ensuring that such employees are “social media savvy” and understand social media risks.
TYPES OF SOCIAL MEDIA USED BY BANK
Currently the Bank utilizes Facebook, Youtube, Blogger, LinkedIn, and Twitter. These platforms provide for varying types of interaction. Some are more information based such as LinkedIn. Others are more collaborative, such as Facebook. Currently the Social Media Manager is responsible for managing these accounts.
OTHER FORMS OF SOCIAL MEDIA
Regardless of any organization’s use of social media, Internet users can make comments that affect the Bank on locations outside of the Bank’s social media sites. As such, the Bank utilizes Google Alerts and SocialMention.com to monitor (listen) to conversations in social media and on Web sites that may affect the Bank. Such reports are delivered directly to the Social Media Manager on an ongoing basis. The Social Media Manager is responsible for determining appropriate action, if any.
On at least an annual basis the Bank will provide social media training to all personnel. The training is intended to convert employees into social media evangelists while ensuring safe and sound use of social media. Compliance with the guidelines noted above will largely ensure that employees act in a manner consistent with Bank expectations.
The Bank’s social media activities will be audited as part of the Bank’s normal internal audit schedule. Auditors will audit as appropriate. For example, audits related to IT, consumer compliance, fair lending and CRA may all contain a social media component.