Woodruff Sawyer’s “Implementing a Corporate Social Media Policy” provides an overview of the why, how, and what, of developing and regularly refreshing a standalone social media policy with reference to relevant regulatory considerations and examples.
The post suggests such policies include or address:
- Purpose of the policy and scope of applicability (see, e.g., P&G’s Global Social Media Policy)
- Description of confidential information, which should be aligned with the company’s Insider Trading Policy
- Cross-references to other related company policies such as Insider Trading, Reg. FD, and Confidentiality policies
- Authorized company spokesperson with reference to the company’s Regulation FD Policy (see, e.g., Wolters Kluwer’s Social Media Policy/Global Standards)
- Acceptable and unacceptable conduct, which the firm believes is most effectively communicated by examples (see, e.g., Edmunds’ Social Media Guidelines: Rules of the Road)
- Contact(s) for questions about the policy
Like all other policies, social media policies should be slated for regular review (the firm suggests at least annually, as well as in connection with certain circumstances such as M&A transactions) for potential updates based on developments in the business or regulatory environment, and actual incidents that may inform changes in how certain policy provisions are expressed or provide additional helpful examples to include in the policy. Any substantive modifications should be communicated promptly to employees and others covered by the policy.
See “Companies and workers face off in return-to-office battle as employees air their grievances on social media” (Fortune) and additional resources and examples on our Social Media page.
This post first appeared in the weekly Society Alert!