Last week I was invited to be part of an My Community Manager / emoderation panel discussing social media in regulated industries.
I thought it might be worth providing a transcript of my responses here (since I’ve taken the time to prepare them, I may as well blog them too!)
Please bear in mind I was talking primarily in relation to Financial Services.
Q. There is no doubt that highly regulated companies tend to avoid social media because of compliance or legal concerns. What are the top three things regulated brands should consider when creating a social media management strategy?
- Bring legal and compliance into conversations from the start – hear them and address their concerns. Their concerns are real and you need to define appropriate ways to manage them from the off
- Get on top of the compliance requirements for social yourself – don’t rely on your risk team to own that element – you need to understand what you can and can’t say if you are to define effective processes, governance and training
- Plan for exceptions – how will you handle a data breach, a reputational crisis or a compliance issue – work out how you would manage this and build this into your agent training – don’t just leave it to PR
Q. Highly regulated industries such as healthcare, banking, pharma and finance have unique needs that need to be addressed outside of standard social media policies. How do these industries navigate the social media landscape and position themselves to lower the inherent risks?
In a regulated industry that regulation exists to protect consumers. This implies that you have a duty of care to your customers. But rather than being a negative I think this provides an opportunity for social and digital. But too many brands fail to recognise this – they limit their social media activity to bland chit-chat and reactive servicing. If I were positioning my brand, I would base it around that duty of care, focusing on content that educates, informs and protects the customer and proactively looking for opportunities to create better customer outcomes, for example providing account alerts of messenger or simplifying basic transactions through social and mobile channels.
Q. Banking and healthcare industries have access to confidential materials and must be cautious when providing information online in order to stay compliant with federal regulations. This privacy extends to the information that their employees may be posting about the company and/or industry. How do you maintain control over this and what are the biggest challenges?
Probably the biggest challenge here is building that level of understanding around regulatory requirements across the business. That said good governance and training go a long way. Also if you have a clear social media and content strategy you should be planning the bulk of your content in advance, which buys time to ensure it is compliant. Day to day engagement is tougher to manage but in reality how often is an agent going to get their hands on and post confidential or non-compliant information – with a good common content repository, this should not be possible.
Q. How do you recommend that brands meet the challenges in making sure that all outbound content meets established standards (FINRA, FDA, HIPPAA, FTC, FCC, etc.) in order to ensure your content remains compliant?
Good planning means you can create content in advance and have compliance check it over but it doesn’t work for everything – sometimes you will want to create agile content to capitalise on a certain news hook, issue or event that you hadn’t anticipated.
However, not all types of content create regulatory issues – most regulation in FS related to promotions and endorsements – and its usually only sales type content that is at risk here.
I would suggest that this type of content always be planned and checked for compliance and that more agile, ad hoc type content be limited to lifestyle / engagement type pieces that are unlikely to create any issues and do not require sign off
Q. Many heavily regulated companies opt to play it safe by allocating their marketing efforts elsewhere instead of social media – many brands understandably have big fears. How does a social media manager navigate these waters to get key stakeholders invested in their social media plan?
I think it’s a dual approach really:
Firstly you need to show you have done your homework and thought through the risks and have mitigations in place
Secondly you need to show the scale of the opportunity and the benefits it can bring to the business – offset the risks by showing how it can improve customer outcomes and help build trust in the brand
Q. Heavily regulated brands have to ensure they’ve adapted a thorough customer service response plan. For example, adverse event training and certification is a requirement in the pharma industry. What things do you consider when putting together a successful customer service response plan for a regulated brand?
I start with the overall strategy and vision for social servicing and use this to define the workflow processes
I always try to consider every exception and plan for this, so the usual outputs are a long list of workflow documents, governance and guidance materials, that cover things like when and how to respond to different situations, triaging to agents, using the selected social media management tools and tying this to existing CRMs and logs for archiving, how to adopt a brand tone of voice, handling difficult customers, a measurement and quality framework, and so on
It’s also a good idea to create a robust agent selection and accreditation process and training plan so you can scale effectively
Also don’t forget top consider crisis identification and crisis management training and simulations
Above all I work with clients to try and set a guiding ethos to underpin all of the activity – for example, ‘treat customers like they are family’. This can act as a handy compass for agents in their day-to-day activity and can help embed a strong customer service attitude much better than reams of documentation.
Q. Regulatory bodies such as the Financial Industry Regulatory Authority (FINRA), the Securities and Exchange Commission (SEC) and the Food and Drug Administration (FDA), for example, have comprehensive guidelines so that companies can participate in social media and stay compliant. How do social media managers stay on top of these changing guidelines when managing the social media management plan for their brand?
You really need to stay on top of the regulation around content and social media – but it isn’t updated that often and it isn’t that complex on the whole, so it isn’t as hard as you might think. Also, build a relationship with the regulator, they often ask for feedback on guidance and it is your chance to input and clarify on what you don’t understand.
Q. There are organizations that are showing it’s possible to comply with regulations and succeed at great social media. What are some of the brands that you admire in this industry and why do you admire them?
MBNA in the UK – two years ago they had no social media presence and were very risk averse. Now they are active on social and committed to creating added value for customers. In fact they’ve just announced a partnership with mobile provider O2 to provide auto alerts through mobile phones when customers go abroad. This removes the need for customers to notify the bank and prevents MBNA having to block cards when the customers forget.
I love this – this is real customer care!
[Image Credit: James Petts]