"Internal" Social Media: What FINRA Member Firms Need to Know
In this blog post, we'll discuss what has recently been defined as "internal" social media, how it differs from the more traditional and widely adopted "external" social media, and how and why regulatory requirements apply to both internal and external of social media, when in use by regulated organizations.
To begin, let's clearly distinguish between "external" social media and "internal" social media.
External Social Media Applications
"External" social media can be defined as those social media platforms that are external to your organization, in the sense that the main use case of such platforms is to interface with the outside world, performing actions such as responding to requests for information, advertising, and establishing your organization's brand. You're undoubtedly familiar with external social media: linkedin, twitter and facebook are the main players in this category.
Internal Social Media Applications
"Internal" social media differs from external social media in that the primary use case of such platforms is to collaborate with co-workers and colleagues inside your organization. Such collaboration may take the form of an internal sales team sharing comments and strategy about a group of prospects or a customer support team reviewing a customer's support case history. The main platforms that can be defined as internal social media are: Salesforce.com Chatter, Yammer (recently acquired by Microsoft) and Jive.
Now that we've defined internal and external social media, we can discuss the regulatory implications of employing internal social media applications for FINRA member firms.
As employees of FINRA member organizations know, one cannot simply adopt a new technology without first reviewing the potential compliance implications of doing so. In recent years, as regulated organizations have begun to pressure regulators for guidance on social media use, regulators have in turn responded with rules and guidelines that outline how to leverage such technologies while maintaining regulatory compliance.
Cutting through all of the confusion surrounding the matter, the simple fact is that any communication that constitutes a business communication must be archived, regardless of the underlying media employed to convey the message.
Drawing a parallel to email archiving, most firms have found it to be more cost-effective and efficient to simply archive everything, as opposed to having team of people at hand to review each individual communication to determine whether or not it constitutes a business communication.
So, if the underlying medium does not matter (i.e. - paper, email, instant messaging, social media), but the content of the message does, then internal social media must be archived as well if the content constitutes a business communication. Smart organizations and early adopters of social media have built or bought solutions that assist in archiving social media content. This holds true for both external and internal social media.
In our experience, if regulatory requirements cannot be met (read: it is not possible to archive social media content), then smart organizations have shelved their social media deployment projects until a viable solution arrives.
So what should you do? How can you archive your organizations social media content?
External social media archiving can be attained via solutions from organizations such as: SocialWare, Arkovi or HearSay Social. These providers have sprung up in the past 3 years, so this is a relatively new space that will certainly continue to grow.
Internal social media archiving is an even newer space. Some vendors have developed or are currently developing solutions (including the folks here at eDynamics) to archive internal social media content. Salesforce.com Chatter archiving solutions are currently the most prevalent, but solutions for Yammer and Jive will certainly appear in the near-future.
The bottom line, is that if you'd like to employ internal social media, you need to find a means of archiving its content, or risk regulatory repercussions. If you can't find a solution, then play it safe and shelf the project for the time being.
In conclusion, archiving communications that constitute business communications is necessary, regardless of the underlying media used to convey the message. Internal social media use is certainly subject to this rule; as such, the smart move is to delay and social media deployments until you can archive and ensure that regulatory requirements have been met.
For more information about archiving Salesforce.com Chatter content in accordance with industry regulations, please visit: Archive for Chatter