What should I include in my social media policy?
Businesses are increasingly aware of the importance of social media policies in relation to employees’ conduct online. However, a social media policy should also cover business operations and guide employees involved in marketing and sales on what to do and not to do on the relevant social media platform. Recent studies including those by Social Pulse and Online Circle Digital have shown that large Australian businesses are taking this one step further by moving the regulation of social media out of their marketing departments and into a separate department making a fully operational social media governance facility. However, as social media is still a relatively new field where business operations are concerned, many businesses are still trying to understand what the aim of their social media policy actually is.
Businesses considering social media as an avenue for marketing and developing their customer base should have a comprehensive social media policy.
The ACCC has implemented guidelines for businesses that participate and engage with social media. Part of these guidelines includes the ACCC’s recommendations for businesses to:
- not make misleading and deceptive claims;
- remove negative posts about competitors if misleading or deceptive;
- monitor regularly; and
- respond to false, misleading or deceptive comments instead of ignoring them.
The ACCC also provides various examples in its guidelines of when and how businesses may monitor their conduct on social media channels. These recommendations include:
- if a business has 300 staff it should have already designated a specific amount of resources toward monitoring its social media;
- a business with 20 staff, but with over 50,000 followers should also have an adequate amount of resources devoted to monitoring their social medial channels;
- a business of 12 staff and 80 followers would be unlikely to have the same amount of resources devoted to monitoring the business’s social media channels.
Therefore, the right level of monitoring by a business will depend on its size and the social media presence of the relevant business.
It is recommended that for those businesses using social media, their policy should target specific business units that are responsible for the monitoring and publishing of its social media pages. It may be that the social media policy includes matters of corporate governance to ensure that issues are notified to management, when necessary. For example, the social media policy should include specific items relating to the social media platforms they used for the marketing and sales team on the:
- advertisements that they publish;
- comments that are published;
- review process of material that is to be published;
- response times to complaints;
- the process for providing responses to complaints;
- the internal process for escalating certain issues;
- when to remove material that is published by followers; and,
- time frames for monitoring of activities.
The social media policy should guide employees on how to respond to the various activities on the social media platforms and this is best achieved by providing scenarios and examples of ‘Dos’ and ‘Don’ts’.
It is recommended that as social media is a fast moving field, businesses invest in developing a systematic approach to monitoring social media throughout the business so that the process runs smoothly. It is in the best interest of every business to be one step ahead of the game rather than dealing with an ACCC claim or allegations of misleading and deceptive conduct by a third party.
For more information on preparing a social media policy for your business please contact our experienced lawyers (02) 9895 9200.