Credit Union Twitter Risks

Guest post by Amanda Vega, Amanda Vega Consulting

So what are the risks and what can organizations and users do to limit such risk?

• Data leaks of confidential or proprietary information: The information that could be leaked includes identity theft, credit card fraud, business plans, confidential data, information about internal operations of the company and availability of personnel or their schedules.

• Malware and viruses: The use of abbreviated URLs makes it easy for the bad guys to mask links to infected sites and to redirect users to websites that they would think twice about visiting. The setting up of fake services could be used to collect credentials and information from that user.

• Improper use: From a corporate perspective, employees can be a threat if they post information that could impact negatively on the business and hurt its integrity. A wrong post picked up by such a wide audience could become a PR nightmare for that business.

• Impulse messaging can be dangerous especially if the user is irate and doesn’t stop to think about the repercussions of his or her tweet. Sending inappropriate tweets is not recommended.

• It is what the end-user does with Twitter that counts. Tweeters need to pay attention to what they are doing, listen carefully and do not trust every single follower who sends them a message. Humans are the weakest link the security chain.

• Customer care: Businesses need to be careful how they deal with disgruntled customers who may use Twitter to discuss a negative experience they had. With only 140 characters at its disposal, a business should avoid getting into a back and forth match with an unhappy customer on Twitter and encourage the client to use traditional customer care channels. Take the conversation offline.

How to counter risk:

• Every business that uses Twitter or any other social media or networking site should have a strong policy in place (and enforced) that clearly states how it should be used by employees. Warn about possible disciplinary action if the policy is violated.

• Emphasize that online conduct must not violate the anti-discrimination policy or other codes of conduct. Warn that the policy must be read in conjunction with the existing Employee Handbook.

• Include a provision prohibiting any conduct that violates federal, state, or local law.

• Direct employees to bring all questions related to the policy or permissible conduct to management.

• Off Duty Conduct - Employers may have broad discretion in disciplining employees where the employer can show that the off-duty conduct has damaged the business, hurt the employer's interests, or is otherwise inconsistent with the employer's business needs.

Some basic rules:

• Think twice before posting. Employees need to think compliance, integrity, security, then post.

• Access URLs in tweets with care. If there is no real need to check out the site, leave it.

• Show employees what to look out for. How to notice when someone is stalking or attempting to social engineer information.

• Avoid confrontation on Twitter. It is a great tool for customer feedback but may not be appropriate for resolving complex issues.

FTC FINAL GUIDES GOVERNING ENDORSEMENTS, TESTIMONIALS

• Definition of an advertisement has been blurred by the use of social media.

• Advertisements that feature a consumer and convey his or her experience with a product or service as typical when that is not the case will be required to clearly disclose the results that consumers can generally expect. No more safe harbor – disclosure “results not typical.”

• Material Connections – sometimes payments or free products between advertisers and endorsers, connections that consumers would not expect, must be disclosed. The post of a blogger who received cash or in-kind payment to review a product is considered an endorsement.

• To limit liability look for authenticity – real experiences from real customers/consumers.

• Any endorsement, like any other advertisement, is deceptive if it makes false or misleading claims.

• Company sponsored research – if company refers to findings of research organization, the advertisement must disclose connection between the advertiser and the research organization.

Amanda recently presented for TCUL Annual Meeting& Expo (Grapevine, Texas). She is teaching a new course this summer for Southwest CUNA Management School (Fort Worth, Texas) – “Social Media II: Let’s Be Strategic”.

Comments

[Anthony Demangone]

Nice post, and very timely with NCUA's focus on risk management.

[Jonathan Lay]

Great post! Nice meeting you in Grapevine! Looking forward to seeing more posts in the future!

[Janine McBee]

Amanda, thanks for sharing your insights. Excited to be working with you to help credit unions develop and fine tune social media plans. Looking forward to July's class.

[anderson]

Some important points to remember: Any conflicts of interest must be disclosed in postings including Twitter tweets and profiles. Be upfront with any connections or relationships you have with the company or Credit Union branch you are writing on behalf of. Other updates to the regulations include the disclosure of any company-sponsored research, stricter liability for celebrity endorsements, no more ³safe harbor² for testimonials; meaning, the term ³results may vary² is no longer sufficient when making broad claims, and disclosing results that consumers can generally expect. Remember most importantly to be straightforward and transparent.
***************************
anderson
mastercreditcard

[anderson]

thanks for sharing your insights. Excited to be working with you to help credit unions develop and fine tune social media plans&Nice post, and very timely with NCUA's focus on risk management.
**************************************************
anderson
http://www.mastercreditcard.net

[Janine McBee]

Thanks "Anderson" with mastercard.net for joining the conversation. With communication channels evolving at break neck speeds, it take all of us learning and teaching each other to even begin to keep up (or at least to be in the race).