Look around. Maybe you’re in your office, out on the bank branch floor, or maybe even waiting in line at the grocers — regardless, I bet you can spot someone looking at their phone and engaging on social media. Maybe it’s even you… yeah, I see that minimized window.
Officially or not, social media is in your branch. The best way to protect your institution is to create a social media employee policy. In fact, a study by the Pew Research Center found the lack of a social media employee policy increases the odds that employees will use social media during work hours.
And even more shocking, 77% use social media at work regardless of company policy.
Employees are going to use social media. It might not be while they’re on the clock or confined within the four walls of the branch, but the risk doesn’t end there. Social media marries personal and professional lives. Safety comes from embracing this reality and empowering your employee to act responsibly.
Think of social media like a lawn. Take care of it and it will add value and appeal to your house. Leave it unmanaged and weeds will grow, the neighbors will talk, and at some point, you’ll have to address it.
Every social media employee policy should include these basic sections: a code of conduct, do’s & don’ts, and consequences. Here are some copy-and-paste sections you can use to create your social media employee policy.
It's important to be clear about the consequences of violating policies established in the social media employee policy. When you prepare this section, be sure to consult the NLRB social media guidelines. Some employee activity is protected and prohibiting this behavior can put your bank or credit union at risk.
Here is an example of describing consequences in your social media employee policy:
Violating any of the social media employee policy guidelines could result in your termination, expose our institution to risk, or cause damage to our consumers. Any violation will be reported to HR and, depending on the severity, could result in a write-up, suspension, or termination.
If you have more questions about what you can and can't legally do in your policy, during the hiring process, or as a consequence, check out this great article from Monster.
Social media employee policies should reflect your corporate culture. At the end of this article is a list of policies from other businesses. You’ll see that the core ideas stay consistent, but each business discusses them in a way that is unique. The most important thing is that the policy is understood — it could be that the policy is best communicated in a humorous video. Check out this example:
Policy should be set by a committee comprised of compliance, marketing, HR, and IT. Everyone on the committee should review applicable legislation and guidance (FFIEC, FTC, NLRA, etc.). This committee should review the policy after any unanticipated infraction or as they become aware of changes in the landscape.
The policy should live with HR and be reviewed as part of the employee onboarding process, and as part of an annual training.
You should keep a copy readily available for reference. This could be in the break room, or digitally on a shared server.
Social media and user behavior changes quickly. Setting a policy and then leaving it unedited for years exposes your institution to emerging risks. We recommend that you examine your social media policy at least two times a year and after every incident or major change in the landscape.
An example of a major landscape change: Facebook Live (video streaming) is released. A teller is streaming and in the background is a post that displays the APY of your checking account. The qualification language is not visible. The committee would need to discuss this issue, the potential risk it poses to the institution, and what changes need to be made to the policy in order to mitigate this risk. Once the policy has been updated, you should communicate the change to all employees.
