Communication, policy vital to social media records management

As more companies turn to social networks, learn why a clear social media records management policy is necessary to alleviate risk and stay compliant.

The business benefits of social media are well documented. Perhaps most notable is firsthand interaction with customers

to see, in real time, exactly what they think of your company. But much less documented is how managing social media data should fit into your company's strategy.

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One often-cited obstacle to social media records management is that social media content is very difficult to define as a record. Some experts argue, however, that social media content is not excluded from a records management strategy, but instead only expands regulatory scope.

"Companies need to understand that the new, exciting format doesn't change their obligations regarding records," said Diane K. Carlisle, senior director of content development at records management-targeted professional association ARMA International. "Content which qualifies as a record under other circumstances would still be a record, even if transmitted via social media."

As a result, a corporate social media policy is necessary. It should clearly stipulate that when social media is used to conduct business transactions, the transactions are subject to the organization's overall records management policy.

The policy should also be clear regarding who can represent the company via social media, and it should provide instruction on the types of information they can and cannot reveal, Carlisle said. But above all, common sense should rule.

"It's the simple test," Carlisle said. "Would I be embarrassed if these words were the headline on tomorrow's New York Times front page? If so, you should probably re-phrase it. Social media never dies -- and statements can come back to haunt the individual and the company."

Carol Rozwell, vice president and distinguished analyst at Gartner Inc., said when establishing social media records management policies, it's important to communicate with and educate employees on the rules for social media use.

Gartner recommends that organizations develop a framework to deal with social media commentary on relevant topics. Employees, and the company as a whole, need to take into consideration the content type and the intended audience of the social media collaboration, Rozwell said. Above all, it's important to be clear and upfront with employees about social media records management and their role in it.

"Focus on the positive," Rozwell said, "rather than just telling employees what not to do. What is the organization's social strategy? What must employees do to support it? Why is compliance important?"

Rozwell also suggests researching and deploying tools and services that help capture, store and analyze business-related conversations in social media. Ignoring social media records management, or putting it on the back burner, can create unnecessary compliance headaches, she said.

For example, Rozwell points out that conducting business communications via public social media creates business records that could be the subject of a legal discovery process or may require retention in order to meet regulatory requirements.

"Organizations that use social media for communications may be required to retain copies of the content," Rozwell said. "This is a requirement for many government organizations and most financial services institutions."

The compliance case for social media records management

Adelaide C. O'Brien, research director at IDC Government Insights, said not effectively managing social media records could create organizational inefficiencies and noncompliance with the Freedom of Information Act. It may also prevent access to critical operational information required for decision making and deployment of the company mission, O'Brien added.

It's the simple test: Would I be embarrassed if these words were the headline on tomorrow's 'New York Times' front page? If so, you should probably re-phrase it.

Diane K. Carlisle, ARMA International

"Lost records may expose agencies to legal liabilities and/or tie up staff to the point where other government business is jeopardized and may stop work as employees struggle to produce records under court order," she said of not monitoring a business' social media activity.

But even in the face of these consequences, Rozwell reiterated Carlisle's previous point that some organizations still think social media interaction is a vastly different beast than other business communication.

"That's why we suggest clients write their social media policies as extensions to other existing policies such as code of conduct, Internet or email use," Rozwell said. "The rules that apply in one modality also apply on social media."

Company strategy should take into account how the business intends to use social media and address the records issues when implementing the plan, Carlisle said. Retention periods should match for the same types of content, regardless of what format that content is stored in, she added.

But it's important to remember the fine line between solid social media records management and legal concerns, Carlisle said. "There have been some cases where a policy was found to be overly broad and actually infringed on some employees' protected rights," she said. "Legal counsel should always be consulted when developing a social media policy."

But even with policies and employee education processes in place, you need to remain vigilant.

Social media is not going anywhere, and the risk and benefits surrounding its business use are constantly changing.

"The rules and regulations regarding social media are evolving, so pay attention and revise policy as needed," Rozwell said.

Let us know what you think about the story; email Ben Cole, Associate Editor. For IT compliance news and updates throughout the week, follow us on Twitter @ITCompliance.

This was first published in August 2012

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