Call it a social media fail, but late last Friday we posted this picture of an office Halloween costume that made us laugh given the cinnamon rolls in her hair. We thought she totally nailed the costume and used the heading “Nailed Princess Leia.” Unfortunately, we had a technical malfunction and the application that we use to manage social media failed to post the picture. Thus, what came out was just the heading on a Friday night which had totally different connotations than what was intended – the true definition of reputational risk, particularly for a faith and family bank like ours.
Luckily, we got a chance to test our social media procedure, caught it within minutes and quickly deleted the post. Only 17 of you saw it on our social media feeds (Twitter, Facebook, Google+) for which we apologize. Hopefully, now it makes more sense and you can laugh at both the picture and us.
Our point today is that our risk management procedures worked and we publish our gaffe here today so other banks can learn. For that matter, given that we have gotten smarter in the past year on social media, we have also updated our policies and procedures to include best practices from other banks, feedback from our regulators and insight from our auditors.
Should you want to see the latest for your own reference, we have placed a generic version of both a Social Media Policy and Social Media Procedures in our Resource Center. Both these policies and procedures are the latest and should save you time when updating yours. Specifically, these policies and procedures now include the following:
- Two levels of social media training for financial institution employees
- Clearly stated the priority of risks associated with social media
- Included an acknowledgment that social media complaints should be treated in accordance with regular complaints
- Increased monitoring/archiving requirements
- Updated best practices and included how to deal with non-public information on timed destructive social media such as SnapChat
- Reference Board reporting of social media activities
- Included a reminder to be aware of certain types of slang when looking for non-public data outside of the Bank’s social media properties
If you are a financial institution, please feel free to download both the 2015 Bank Social Media Policy and Procedures, and you have our permission to use any of the intellectual property for your own internal use. To the extent you catch errors or feel that we missed something, please let us know as it would be a good way to pay our effort forward.
Coming up, we are planning two levels of internal training for both our line employees and their supervisors. We plan to make both trainings certified and available to our client banks for low or no cost so that you can leverage our effort to assist with your social media compliance. These trainings are tentatively scheduled for February and will include the latest in social media regulatory compliance, monitoring tools, risk management, emerging technologies (Ello, Snapcash, etc.), strategic alignment and effectiveness. Stay tuned to this blog/newsletter for updates and be sure to follow us on Twitter or Facebook to get the latest banking insight in real time and humor (sort of).
Submitted by Chris Nichols on December 01, 2014