June 2012 | Social Media: Blitzed
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FEATURE

Social Media Risk Monitoring: Has Your Organization Been Gazopted*?

By Suzanne Rhulen Loughlin and Karen Masullo


However beautiful the strategy, you should occasionally look at the results.”

Winston Churchill

Gazopt*.  It is the act of having your reputation, your brand, your message, your identity, or a confidential communication co-opted by an unauthorized person or by one who is violating a confidence or trust. How do you know when your organization has been gazopted? By monitoring the social media landscape using the multitude of tools available to you. It is no longer enough to think of social media as solely another medium to market your business. In fact, the failure to monitor social media may mean the end of your organization.

You want to stop reading at this point in the article, don’t you?  ‘The author is over-dramatizing the issue’, you are thinking.  Keep reading. We will convince you that incorporating social media monitoring into your day-to-day practice is necessary to protect both your organization and its clients. Ultimately, the practice of monitoring will become ‘second hand nature’ like Sheppardizing case law.

Why Monitor?

Your organization has likely adopted a web marketing strategy, which includes a robust website, Twitter or Linkedin accounts, and maybe even a Facebook page. The opportunities to engage a broader audience for products and services was- and is- undeniably attractive and has been quickly adopted by marketing, sales groups, and professionals in all industries. 

Why? Consider the Following Statistics:

  • 1.2 billion users worldwide
  • 82% of the world’s internet population over the age of 15 -- now log on to a social networking site.
  • 1 in 7 minutes online is spent on Facebook (more than 8 million users (comScore, Facebook)
  • Twitter has over 100 million active users (State of Search)
  • Mobile internet users will reach 113.9 million in 2012, up 17.1% from 2011 (HubSpot)
  • Twitter is adding nearly 500,000 new users per day (Jeff Bullas)
  • Google Plus is adding 625,000 new users per day (PC World)
  • There are more than 135 million professionals on LinkedIn (LinkedIn)
  • Over 3 billion videos are viewed on YouTube everyday (YouTube)
  • More than 3/4 of the total population will be online in 2012 (HubSpot)

As the audience continues to increase and new social media tools continue to emerge, the risks that organizations have always been vulnerable to are enhanced. Furthermore, the line between business and personal communications has become blurred, further exposing your organization to liability.

Today, more people have a voice than ever before. Their communications and interactions are instantaneous and far reaching. As a result, social media risk mitigation is fast becoming a field of expertise unto itself. Facebook, Twitter, Google+, LinkedIn, vanity websites, blogs and other forms of social media are virtual (and permanent) warehouses of evidence. Understanding how to monitor these communications and interactions will enable you to both assess the risk and reap greater rewards through richer engagement.

As social media use has grown, we are seeing regulators, like FINRA, promulgate regulation to protect investors; the SEC issue notices which provide guidance for using social media in the context of regulated business transactions;.; and the IRS,  using social networking sites and tools, like Google, to investigate tax payers and to value transactions. (If they are researching your clients, you need to as well.)

Also notable, is the ever increasing body of case law emanating from social media risk, including claims of defamation and copyright infringement; discrimination; breach of non-compete agreements; employee misrepresentation on social media sites - all with significant consequences, including associated judgments, fines and penalties.

There are financial implications as well.  A Symantec survey (July, 2011) quantified some of the costs stemming from a social media ‘incident’:

  • reduced stock price (average cost: $1,038,401 USD)
  • litigation costs (average cost: $650,361 USD)
  • direct financial costs (average cost: $641,993 USD)
  • damaged brand reputation/loss of customer trust (average cost: $638,496 USD)
  • lost revenue (average cost: $619,360 USD)
  • in addition, more than 90 percent of respondents who experienced a social media incident suffered negative consequences as a result. 

In light of the ever mounting regulatory, legal, and financial pressures, the management of social media risk must be approached in your organization with a mature plan, a mature team, and the flexibility to quickly adapt to or disregard rapid-launch, new technologies and tools as appropriate to a specific organization.  Your organization must be positioned to be ready to respond to a threat or incident before it occurs. 

What is Monitoring?

Monitoring is the process that keeps you on top of what others are saying about your organization, your brand, your results; it alerts you to on-line customer requests and comments, and when on-line responses are expected in return. It keeps you informed of relevant industry discussions, data, and opportunities; it positions you to track your competitors, or learn what your employees are saying to one another about your organization and clients.

The effort to manage a solid Social Media program can be time-consuming and challenging. As a result, a broad range of measurement and analytic tools have evolved to meet the needs of Social Media Management (SMM). 

The majority of these tools measure your social media “reach” and the growth or shrinkage of your audience. Some measure more complex metrics such as how often content has been viewed or redistributed, audience demographics, user sentiment, and conversions to actionable sales activities. Others allow the publishing of content to - and management of - multiple accounts, accessed by multiple team members. It is only recently that we have seen the emergence of more sophisticated tools that track, measure and allow customized search of the broad reach of a brand across multiple social platforms including competitor analyses, and the ability to focus in on, engage in, and measure the effectiveness of very specific conversations and activities.

The Who, Where and When of Monitoring

It is critically important that any social media effort and investment be a collaborative undertaking with investment from organization leadership. Critical too is that the actual “voice” or “voices” of the organization be represented by professionals with the experience and maturity to recognize ‘risk behavior’ related to internal or external interactions, and respond or escalate appropriately. 

Recruiting a part-time intern or hiring a summer associate to represent the organization in its social media management initiative, while cost-effective, may not be in the best interests of all involved. Additionally, the ability to manage complex internal communication needs of all stakeholders and use sound judgment to weigh underlying sources and veracity of social content, are key attributes of those directly responsible for publishing content via social media.

The How of Monitoring

Given the above, the following areas warrant consideration for monitoring:

Monitoring and Securing Brand Monitoring for your Brand is not simply a matter of searching for your company name.  There have been many documented cases of entire websites – images, content, everything – being lifted and replicated without the original site owner’s knowledge. 

  • SmartyPig.com is one of the more well-known instances. SmartyPig, an online social savings company that bills itself as a "free online piggy bank," was named to Entrepreneur Magazine's "100 Brilliant Companies" list for 2011.  Fortunately for SmartyPig, its brand advocates found a “copied” version of its site out of Romania - “TrustyPig” - in 2008, and not only alerted the company, but marshaled the entire web community to eradicate it. The result was that the “fake company” significantly changed its website, and now no longer exists.

Brand “Hijacking” can go both ways – not owning your brand name(s) across all social networks is a common mistake.  Even if you do not plan to use a specific social tool, own your brand on that tool. Does Mattel own the Barbie brand on Twitter? No.  Greenpeace does, and they are not a fan of Mattel.

Immediate Engagement and Alerts: You’ve seen the commercials: “That is so 17 seconds ago.” Social media has created an overload of messaging and millions of “news-desks of one.” As a result, it is imperative that a social media monitoring tool provide real-time or near real-time monitoring and alerts to foster immediate engagement (and damage control) as needed. How long is it acceptable to your organization for a negative review posted by a client to remain visible to the world?  How long is it acceptable for confidential client information breached by your organization to remain public? In social media, the whole world is watching all of the time:

  • Consider the response time difference between two separate Twitter account hacks; those of USA Today and Fox Politics; while the Fox Politics twitter account made no response nor removed offending messages posted by the hackers for more than eleven hours, USA Today removed the hacker false tweets and responded within thirteen minutes.

Logical Workflow: Different social tools are used by varied audiences – an organization’s clients and employees on Twitter may not be the same as those on LinkedIn, although there may be some overlap. Robust social media monitoring tools also provide a logical workflow that makes it simple to alert the right person within an organization to take appropriate action. In addition, there are social media tools that allow one message to simultaneously appear on multiple social media sites, which could be advantageous during a crisis or when countering misinformation.

Integrating your Organization’s Crisis Management Plan with these tools will ensure the most rapid response and reaction from the right people who can directly impact the outcome.

Applications Monitored: Most social media monitoring tools address primary social networks and analytics: Facebook, LinkedIn, Twitter, Google+ and Google Analytics.  Many include pick-lists of a variety of other sites a well. Monitoring these applications is important for a variety of reasons:

  • Employee communications: There is no longer a clear delineation between personal and professional use of social media. Therefore businesses need to know what their employers are saying.  In fact, regulators agree. FINRA clearly outlines that in the financial services industry, there is no line of demarcation between a registered representative’s personal and professional use of social media.  FINRA also defines a LinkedIn profile as static content that requires pre-approval. See www.actiance.com/news-events/press-releases/archive-2011/linkedin-static-content.aspx

      • The Courts have relied on postings on social media sites in their adjudication process:

  • In Park W. Galleries, Inc. v. Hochman, a court concluded that an individual could have been speaking on behalf of his employer, a gallery, when he posted allegedly defamatory statements on his blog. The court determined that there was sufficient evidence to support the existence of an agency relationship between one of the individuals when he made the allegedly defamatory statement.  The evidence cited by the court was a posting on the individual's LinkedIn profile, on which he had identified himself as a "Consultant/Writer at Park West Gallery."  No. 08-122471, 2010 U.S. Dist. LEXIS 12488, at *15 (E.D. Mich. Feb. 12, 2010).

Complexity : While the home web page of a chosen monitoring tool may appear clean, contemporary and well-designed, the application itself may prove overly complicated for even the most sophisticated user.  Make sure the actual end-users in your organization are involved in the buying decision, and that it meets all internal and external monitoring needs.

Engagement : Social Media is, at its core, about engagement.  It allows instant access to customers and clients in a manner that was never previously attainable.  It allows you to listen and respond – immediately.  It allows you to zero in on specific issues, questions and concerns and respond in an unprecedented manner. Nevertheless, many organizations and companies of all kinds have yet to truly grasp the power of listening to and engaging with their audiences.  Rather, they broadcast outbound messages only. Social media, as its name suggests, mandates two way communication; it has revolutionized and streamlined the way to create and develop trusted relationships.

Record-Keeping and Reporting:  As social media use in your organization grows, so too will the requirements for reporting. Types of data to include may measure social audience sentiment, mentions, conversions, competitor analyses, and a variety of other data important to your organization and industry regulators. Carefully consider the ability to easily mine data and deliver results in multiple combinations and reporting views.

All regulated businesses that use or permit the use of social media by their representatives, employees and/or third parties should  periodically evaluate the effectiveness of their compliance program as it relates to social media. Factors that might be considered include: usage guidelines, content standards, sufficient monitoring, approval of content, training, etc. Particular attention should be paid to third party content (if permitted) and recordkeeping responsibilities. (www.sec.gov/about/offices/ocie/riskalert-socialmedia.pdf)

Remember, a communication or content that is subject to disclosure is not altered by the fact that such content was delivered through social media channels. They are no different from other types of communication.

  • NASD Rule 3010:
      • The obligations of an organization to keep records of communications made through social media depend on whether the content of the communication constitutes a business communication- even those conducted through personal devices. FINRA Regulatory Notice 11-39, 08/2011:
      • Each organization must establish and maintain a system to supervise the activities of each associated person that is reasonably designed to achieve compliance with applicable federal securities laws and FINRA rules. As part of this responsibility, a registered principal must review prior to use any social media site that an associated person intends to employ for a business purpose.
      • An organization should not include a link on its website to a third party site if there are any red flags that indicate the linked site contains false or misleading content.
      • Organizations must adopt procedures to manage data feeds into their own websites.

Global/Multilingual : Global organizations with global clients and employees must have the ability to track social media mentions, campaigns and sentiment worldwide in multiple languages, especially in a crisis situation. If your organization has offices outside the US, trying to track what is going on in the wake of a disaster is daunting. 

  • From www.telegraph.co.uk: “Even the US State Department resorted to using Twitter to publish emergency numbers, and informing Japanese residents in America how to contact families back in Asia. Relief organizations used Twitter to post information for non-Japanese speakers to lists of shelters for those left homeless.”

Triggers and Response : Social Media Monitoring Tools are effective and integral to a social media strategy. Yet, they are only as effective as those individuals that maintain them.  Understand what you are monitoring and why, and know what the ‘triggers’ are to take action. Designate the team that will respond, including third party vendors who have capabilities that may not be resident in your organization; document and train on the action steps, and be ready to implement immediately. Without these plans and procedures in place—tools are just tools- like those gathering dust in your garage.

  • “There are countless examples of corporations that do not have a listening strategy to respond to online and traditional media simultaneously. This type of tunnel response strategy can backfire and create a full-blown crisis that could have been prevented. These issues are largely due to internal in-fighting over who really owns social media within the organization: PR, advertising, IT or social media experts? The answer is that all of these departments must work together to fashion a response for the good of the company.” From Adele Cehrs, President Epic PR Group for commpro.biz

The Bottom Line

The greatest risk for your organization regarding social media is in not understanding that EVERYONE in your organization who leverages social media OWNS SOCIAL MEDIA. Therefore, EVERYONE in your organization must be trained on the organization’s internal policies and regulations that apply. Moreover, EVERYONE’S ACTIVITY MUST BE CAREFULLY MONITORED, and where necessary, retained and indexed, as ORGANIZATION LEADERSHIP WILL BE HELD ACCOUNTABLE.

Fortunately, there are many tools to help you do this.  The adoption of such tools, and most importantly, the diligent use of those tools, will position your organization to not only assess the results of its marketing efforts and strategically monitor your client matters, but most importantly, assure that your organization will be able to quickly respond to damaging statements or comments posted by third parties, competitors, employees, or most significantly, the reputation of your organization or its employees.

Back to the esteemed Mr. Winston Churchill:

“To build may have to be the slow and laborious task of years. To destroy can be the thoughtless act of a single day.”

Were he alive today, the quote would undoubtedly have been modified:

“To build may have to be the slow laborious task of years. To destroy can be the thoughtless act of a single tweet.”

*Gazopt: From the Hungarian “Gáz”: awkward, miserable, problematic and the English Co-Opt: to commandeer, appropriate or take over.

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About the Authors

Suzanne Rhulen Loughlin is a Founder, Chief Administrative Officer and EVP of Firestorm® Solutions, LLC, a recognized leader in crisis management, vulnerability analysis, risk mitigation and business continuity, which serves Fortune 100 clients, as well as small businesses and governmental entities.

Karen Masullo is EVP, Social Media for Firestorm Solutions, LLC. In addition to serving as Firestorm Solution’s own in-house social media advisor, she also serves on the Firestorm Solutions.

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