Social media policy: what not to do: one way to develop a policy is to take note of the approaches that you should steer clear of.

• Author: Schelfhaudt, Carie

WRITING A SOCIAL MEDIA POLICY THAT SATISFIES THE NEEDS OF HUMAN RESOURCES, marketing and compliance can be an intimidating task--especially considering that an industry standard doesn't yet exist. But have no fear! By knowing what not to do, the process of creating a policy can be made much easier.

Here are a few key "dent's" to keep in mind when drafting your policy.

Don't be vague.

Perhaps because precise regulations regarding social media have not been introduced, many bank marketers take a casual approach in their social media policies to keep it simple. However, vague statements can create big problems, according to the National Labor Relations Board (NLRB).

The NLRB has been studying social media issues, particularly with respect to what employers can or cannot do with social media policies (for example, can an employer fire an employee because of something the employee posted on his or her personal Facebook page?).

According to a recent report by the NLRB acting general counsel, six out of seven company policies contained information that was "over broad and thus unlawful under Section 7 of the National Labor Relations Act."

As a result, banks need to specify in their social media policies precisely what type of content is permissible if shared online and what type of content is not permissible (examples of possible prohibited content: discussions of employee wages or working conditions).

To best meet regulatory guidelines, Tom Tuniewicz, vice president of compliance and security officer at Clinton Savings Bank (assets: $479 million), Clinton, Mass., suggests that banks should be as specific as possible and create a social media policy that follows the same rules that apply to all bank promotional and advertising materials.

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Tuniewicz notes, "If banks don't deceive the public and avoid vague or misleading information, we should have an easy road ahead."

Specifically, he says, "If we adhere to the spirit of avoiding Unfair, Deceptive, and Abusive Acts and Practices and all the disclosure requirements--like those in Truth in Savings (Regulation DD), Truth in Lending (Regulation Z), Equal Credit Opportunity Act (Regulation B), the Real Estate Settlement Procedures Act, to name a few--we can maintain compliance."

To ensure that employees fully understand the bank's social media objectives, we further recommend that banks provide detailed reasoning for being present on each social networking site and the way the...