Using+Social+Media+to+promote+C&E

===[Click here for the related "Compliance Concerns With Social Media" page] ===

====A little searching on the Internet will show you that the words most often associated with “social media” and “compliance” are “danger” and “risks”. The focus for most still seems to be on trying to control, rather than promote use of social media in the workplace, much less as part of the Compliance and Ethics effort. ====

====But if this latest report from the Ethics Resource Center (registration required to access the full report) is correct, 3 out of 4 of your employees are using social media every day (often at work). and a percentage of the workforce sampled was on some social networking site __all day long.__ So wouldn't it make sense to have your ethics and compliance message where they are? ====

**First, get comfortable with promoting Social Media Use**
====If your organization - like many - is blocking employees from using Facebook, you may want to take a look at other possible policies. ====

====One interesting leader in this area is an “old school” company – **IBM**. Here are its “Social Computing Guidelines” which state the expectation that: ====
 * ====“it is very much in IBM's interest—and, we believe, in each IBMer's own—to be aware of and participate in this sphere of information, interaction and idea exchange” ====

====Also check out their training video and note the tie-back to the company’s business conduct guidelines and core values. Yes, it really is that edgy – and here’s a case study on how it got that way. ====

====**Dell** is another encouraging company. Its policy also incorporates its values, Code of Conduct and ten magic words. ====

====**The Veterans Administration** has also adopted and "highly encouraged" the use of Social Media, with the goal of creating an "interoperable, net-centric environment by improving employee effectiveness through seamless access to information". It's 21 page "directive" has detail on roles and responsibilities for supervisory personnel in creating that environm ent. ====

**Second, study and advocate for Social Media’s benefits**
==== A primary goal of the **Mayo Clinic** is helping patients “get the best information, connect with providers and with each other, and inspire healthy choices.” That’s part of why it started its Center for Social Media. Check here to see if your healthcare organization is part of its Social Media Network. ====

==== The current CEO, Dr. Noseworthy, has been a strong advocate for this part of the organization’s activity and willing to talk in public about why he supports it. Mayo social media efforts presently include a Youtube channel, a Twitter feed, a Facebook page and more than a dozen blogs, both internal and external, including ones for patients and employees to share stories about Mayo. ====

====Others in healthcare have thought about how Social Media can be used for medical and patient education. Here's a 2013 Grand Rounds presentation and "4 Reasons to Ban Social Media in Your Hospital" ====

==== By way of contrast, the Cleveland Clinic has a slightly different approach to Social Media and your customers and patients will have their own views of your social media strategies. ====

**Integrating Social Media into Ethics**
====**Best Buy** has had separate ethics and compliance functions. The former was led from 2003 - 2014 by Kathleen Edmond, its Chief Ethics Officer, who used social media extensively (1) to break down the message shifting that occurs in large organizations ( “the company says”, “corporate says”, “legal says” ) and (2) to create a connection to Best Buy leaders as people. (Ms. Edmond stepped down from this role at the end of 2013 and in now of counsel to a law firm in Minnesota). ====

Specific strategies included –
====A 2010 presentation by Ms. Edmond and her colleague Gil Dennis posted on YouTube had many more details but has been taken down. But this 2013 article - Best Practice at Best Buy: A Pioneering ethics blog of employees (David 2013) is still available. ====
 * ====Leaders tweeting and blogging ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;"><span class="wiki_link_ext">Iambestbuy.com ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Permitting hotline reports via text ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Leadership dialogs – online, Skype, face to face ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Bestbuyethics.com (aka “Open and Honest” – its reporting portal) ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Kathleen Edmond.com (outside the Best Buy firewall, now closed) ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Blue Shirt Nation discussion board (now closed) ====
 * ====<span style="color: #000000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">a Google+ "Hangout" to introduce the Compliance team and issues for 2013 ====

====<span style="color: #ff0000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">And here is a 2014 statement about Best Buy's Social Media Policy - Be Smart, Be Respectful, Be Human ====

<span style="color: #ff0000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">YouTube Uses -
====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Here is HCA SVP and Chief Ethics and Compliance Officer, Alan Yuspeh, using YouTube to talk about the significance of his company's repeated receipt of the Ethisphere "Most Ethical Company" award. The video is done looking directly into the camera but not shot in a production studio - and that also carries a message. ====

====<span style="color: #ff0000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">The University of California at San Diego Health System has created a short video about its Mission and Vision which is available on YouTube and linked to its recent job posting for a Director, Corporate Compliance - on Linkedin. ====

====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">And the NY City Conflicts of Interest Board has started an "Ethics Express" YOUTUBE campaign, training about COI in segments that are five minutes or less. The trainers ask questions of experts, capture their answers and leave the watchers with methods to follow-up and learn more. ====

Learning more:

 * ====<span style="color: #000000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Thomas Fox has also written about how Social Media may be part of a compliance effort in "Ethical <span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Leadership: Leading A Company Conversation On Compliance"(2012) and Getting Your Employees to Internally Market Your Compliance Program (Fox 2013). ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Using Social Media to Boost Ethics and Compliance (Babcock 2013) has some points about what others our doing with SM. ====
 * ====And <span style="color: #000000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Doug Cornelius shared his thoughts and some great research points about Social Media and Compliance in this 2009 presentation. ====
 * ==== Social Media may also have a role for public companies in meeting their responsibilities under Regulation FD to broadly disclose "material information" as this article by Richard J. Sandler describes. ====

**Social Media as Part of Due Diligence**
====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">“The organization shall use reasonable efforts not to include within the substantial authority personnel of the organization any individual whom the organization knew, or should have known through the exercise of due diligence, has engaged in illegal activities or other conduct inconsistent with an effective compliance and ethics program.” (Federal Sentencing Guidelines for Organizations) ====

====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Given the rapid growth and widespread use of Social Media, at least by individuals, the standard for “due diligence” may well already include viewing social media sites as part of an appropriate background check. But there are compliance concerns with doing so as well – potential exposure to information that can be used for discrimination and application of the Fair Credit Reporting Act in the event that information obtained through social media results in an “adverse action.” As with any compliance related function, starting with agreement by getting down “the rules” in a policy format and then training those involved about the procedures and the reasons behind them is advisable. ====

**Social Media Background checking resources:**

 * ====<span style="color: #ff0000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Social Media Is Part of Today’s Workplace but its Use May Raise Employment Discrimination Concerns (EEOC 2014) ====
 * ====<span style="color: #ff0000; font-family: Arial,Helvetica,sans-serif; font-size: 110%;">The Fair Credit Reporting Act & Social Media: What businesses should know (EEOC 2011) ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Social Media History Becomes a New Job Hurtle (Preston 2011) ====
 * ====<span style="font-family: Arial,Helvetica,sans-serif; font-size: 110%;">Legal Issues Surrounding Social Media Background Checks (Sherman 2011) ====

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