Social Media Guidelines: In Pursuit of a Policy

Peter Houston

A few weeks back I wrote on this blog about the need for CEOs to get social. I’m realistic, I know that the majority of CEOs still don’t engage directly in social media. Mostly it’s “the team” that does it, the marketing team, or the social media team, or the whole team. Great. Have you told them what rules they’re playing by?

Back in October 2010, Pharmexec reported on a bold new initiative by Swiss drug maker Roche. They had taken the bull (maybe a cow in Switzerland) by the horns and published a set of internal guidelines on when, where, and how to apply social media tools when communicating with key stakeholders and the public.

The guidelines were a real novelty at the time, the first in the industry. Even now, almost two years later, transparent standards for online behaviour are not exactly de rigueur for Pharma… or anywhere else for that matter.

Numbers vary but there is a broad consensus that written social media policies are absent or poorly communicated. Research conducted by the Center for Marketing Research at the University of Massachusetts Dartmouth for the 2012 Inc. 500 Social Media Update found that a huge majority of INC. 500 companies plan to increase their social media spend this year, but that only 24 percent had a written policy for employees using social media tools on behalf of their company.

Late in 2011 Grant Thornton reported similar findings: More than three-quarters of 140-plus companies responding did not have a clearly defined social media policy.

More recent research from the UK seems much more positive. A study by social media consultancy Immediate Future on the adoption of social media policies showed just 19 percent of companies didn’t have a formal policy. However, whilst more than 80 percent of businesses had a policy in place, for many it was out of date, still in draft or, most important, not well communicated to employees.

Poor communication of policy is noted as a particular problem by Kirsten Liston of SAI Global’s Advisory Services team. Offering tips for developing a corporate social media policy on the Corporate Compliance Insights website, Liston says that the prevalence of social media has increased the risk of compliance violations and that it’s important that employers and employees understand those risks. Regulatory restrictions specific to Pharma are much debated, but what about more prosaic infringements. It used to be you only had to worry about employees with computers on their desk. Now, with the spread of smartphones, everyone is a potential risk. Instagram photos from the lab or the manufacturing floor anyone?

But don’t think you can throw a blanket ban over the problem; simply forbidding employee discussion of their jobs is no longer an option, at least not in the US. A recent National Labor Relations Board pronouncement says employees must be allowed to discuss working conditions freely, whether at the workplace or on Facebook.
So it’s all about striking a balance. If you think this all sounds like too much effort to mitigate a hypothetical risk, here are a couple of quick examples of corporate social media screwups.

You may have heard that UK music retailer HMV recently laid off almost 200 people earlier this year. If you did it’s probably because Poppy Rose, the community manager in charge of the company’s Twitter account, broadcast a blow-by-blow account on Twitter, including tweets like, “Mass execution, of loyal employees who love the brand”. While HMV gained 10,000 followers during the “broadcast”, the company’s management was widely pilloried for mismanagement.

Then there’s the case of Dr Amy Dunbar, an ob-gyn working at St. John’s Mercy Medical Center in St. Louis. She posted on Facebook about a patient’s tardiness. Asked why she didn’t transfer the patient, she divulged that the patient had suffered a stillbirth in the past. Dr Dunbar was not found to have breached any regulations, but criticisms of unprofessionalism and hypocrisy on the part of the hospital authorities were very public.

Would a social media policy have prevented these cases? Probably not in the case of HMV, where a judicious change of passwords ahead of the layoffs would have been much more effective. Probably yes in the St. John’s case.
The trick is to achieve the standards that you need without limiting your company’s social media potential. Roger Estafanos, director of Life Sciences for Peppers & Rogers Group’s Healthcare practice recommends pharma companies take a customer-centric approach to social media activity.  Understand your audience, the channels they use, and what they are interested in. Then, you guessed it, allow employees and the public to participate within those “rules of engagement.”

In developing your rules of engagement, remember you’re part of a heavily regulated, competitive industry, not set up for “instant unfiltered communications often seen in social media channels” as described by Snell and Wilmer on Martindale.com. Their advice is to work closely with your legal and marketing teams to maintain an up-to-date social media policy.

If you need a starting point, there are 30 policy examples on Immediate Future’s blog and Edelman SVP David Fleet offers up a long list of examples and how-to resources on his blog.

While the task of formulating a serviceable, and sustainable social media policy is daunting, the potential benefits of enhanced social media participation outweigh the challenge. Imagine you get it right and every one of your employees becomes an advocate for your brand online.

My personal advice, talk about social media regularly and keep it simple. There is a certain irony in companies publishing a social-media policy 25-pages long to regulate a 140-character tweet. How about this? “Don’t say anything online that you wouldn’t want to see quoted on CNN, be asked about by your mother or have to justify to your boss.”

I found that on Twitter; you can have it for free. You’re welcome.

Peter Houston is former Group Content Director for Advanstar Pharma Science. He is now an independent media consultant and founder of Flipping Pages.