From the March/April 2011 issue of Ethikos
Think Before You Tweet: Social Media Codes of Conduct
When Best Buy Company, Inc.’s social media policy was developed two and a half years ago, there was a great deal of debate as to whether or not the company even needed one.
In the face of a rapidly expanding social media environment, one that had grown to include outlets like Facebook and Twitter, the general consensus was that yes, it was necessary.
Best Buy’s public relations, marketing, and legal departments outlined a set of guidelines meant to identify the company’s primary concerns regarding social media. It was originally called ‘Blogging Guidelines’ but as time went on, it became clear that ‘Blogging’ was a limited terminology. It was renamed ‘Social Media Policy,’ but as it grew in scope, it expanded into Best Buy’s ‘Social Media Guidelines.’ It is one and a half pages, and subject to constant revisions as social media trends and outlets continue to evolve.
Kathleen Edmond, the Minneapolis-based company’s chief ethics officer, refers to it as the “Don’t Be Stupid” policy.
“Some companies have policies that are seven pages long, and you CAN’T do that,” she says.
A social media policy, Edmond says, needs to be directed to employees at all levels. It needs to be clear, concise, and easy to follow.
It also needs to be flexible. With an area that moves and evolves as fast as social media, a policy has to be adaptable as modes and issues change. Edmond tells the following story:
An employee is suspended
A year and a half ago, a Best Buy employee created a humorous online cartoon titled “iPhone 4 vs. HTC Evo.” The video, uploaded on YouTube, follows a cartoon animal as he attempts to talk a customer out of buying an iPhone 4. The cartoon went viral. Best Buy executives recognized the video’s creator as a Best Buy employee. While the offending iPhone vs. Evo video made no references to Best Buy per se, the employee was suspended on the grounds that the video spoke disparagingly of one of the brands carried by the retailer (i.e., the iPhone).
Best Buy’s human resources (HR) department investigated the issue. The employee was eventually allowed to return to work. The original iPhone vs. Evo video remains online. However, knowledge of the investigation circulated almost as quickly as the original video, which received more than 62,000 views.
“Our response was a little jagged,” acknowledges Edmond. “Our reaction was slow, and our goal is to improve on that. Lots of employees weighed in on the iPhone vs. Evo cartoon, and as a result we had employees saying, ‘We would like to form an expert group that checks out content if disciplinary action has to be taken.’” Such a group is being formed.
Three short statements
Overall, Edmond views Best Buy’s policy as a step forward. It’s aimed at all employees that use social media. “Which is practically everyone,” she admits.
Best Buy’s social media policy is summed in three short statements: “Be Smart. Be Respectful. Be Human.” Most of the guidelines are intuitive—akin to the sort of instruction that parents will give to children when they discover the Internet: Be careful of what personal information you share online and “don’t misrepresent yourself.”
Beyond that, Best Buy’s social media policy requires that employees discussing their job on an online forum disclose their position and responsibilities at Best Buy. They are not allowed to disclose company numbers, details about upcoming promotions, or personal information related to Best Buy customers: in essence, anything that violates Best Buy’s privacy policy.
These responsibilities extend beyond company hours: “Remember,” the policy details, “Your responsibility to Best Buy doesn’t end when you are off the clock.” For that reason, this policy applies to both company-sponsored social media and personal use as it relates to Best Buy.”
Intel’s policy: ‘Not a right but an opportunity’
Other companies also strive to develop a social media policy that is smart, respectful, and human (in Edmond’s words)—but also effective.
“The issue is that everyone within a company wants to be as restrictive as possible to ensure they mitigate the risk, but there is a fine line here. You don’t want to put your employees in a small box,” says Ekaterina Walters, e-communication strategist at Intel Corporation (Santa Clara, CA). “You want them to be creative in how they are addressing issues/complaints/problems, and you just want to ensure they know the basics of what’s appropriate and what might potentially put the company at risk.”
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Under the section labeled ‘Your Responsibility,’ Intel’s social media policy is clear: “At Intel, participation in social computing on behalf of Intel is not a right but an opportunity,” it reads. “So please treat it seriously and with respect.”
At approximately four pages, Intel’s social media guidelines cover issues of code of conduct on all social media outlets available to employees, but it goes one step further in laying out a specific set of guidelines focusing on employee participation in Intel’s many active social media programs.
It’s a hard balance to strike, Walters admits. But it’s just as hard to predict where the conversation will go, so you just have to be prepared. “Always have your contingency planning (risk planning) done to ensure you have a team/process in place to address whatever can come your way.”
Intel supports a network of employee-run blogs (http://blogs.intel.com) whose stated purpose is to “share their perspectives and invite discussion on the issues they and our customers are facing today.” Participating individuals range from a senior systems engineer to digital marketing specialists. Employees offer input and information for the blogs’ various columns, which focus on technology and consumer interests. Discussion may range from the latest consumer rankings on netbooks to the educational uses for the latest smartphones. Customers and other employees leave opinions and comments in response to these entries. Some of the columnists go further, providing links to personal Twitter and Facebook pages in their blogging profiles, available on the ‘about us’ section of the blog.
And what are Intel’s requirements for participation? Intel social media practitioners (SMPs) are required to complete what is referred to as Digital IQ training. “We designed a mandatory 30-minute class for those at Intel who want to become a social media practitioner and who want to engage with our customers online on behalf of Intel,” notes Walters. “The combination of strong policy and good training that covers all the critical elements employees need to remember provides a great framework for employees for appropriate and effective engagement.”
This class, called Digital IQ 500, is one of over 60 classes that have been created as a part of Intel’s Digitial IQ training program. The classes cover a range of social media topics, from viral marketing to a basic crash course in Twitter. To date, Intel has trained over 2,000 SMPs through the Digital IQ 500 class. Approximately 20,000 employees have participated in the generic Digital IQ training program.
JetBlue: No blogging during work hours
JetBlue Airways (New York) is another company that has wrestled with social media policy questions.
JetBlue’s stated social media policy is 600 words. In it, employees are asked to be respectful, adhere to JetBlue’s confidentiality policies, and clearly identify their opinions as their own and not those of the company. As for social media activity that may occur on company time, the policy is very clear: “JetBlue reserves the right to monitor use of company-provided and company-owned computer equipment. Blogging must not occur during work hours or through the use of company-provided or company-owned computer equipment.”
As for off-hour postings, the policy goes one step further: “JetBlue in its sole discretion will determine whether a particular blog or social network posting violates JetBlue policies, values, or operating procedures. As with all JetBlue policies, a violation of such policy may result in Progressive Guidance, up to and including termination.”
What constitutes a violation? It is dependent on the individual issue. Here, too, some flexibility is allowed.
“There is no overarching, written-in-stone policy at JetBlue,” says Allison Steinberg, digital analyst at JetBlue. “JetBlue likes to operate with a small business mentality.”
Allison Steinberg runs JetBlue’s BlueTales blog (http://blog.hellojetblue.com/blog/). Described as the airline’s “Center of Gravity” for all JetBlue social media outlets, (which includes the airline’s Facebook, Twitter, and YouTube accounts) the blog features weekly travel tips, photo contests, and employee anecdotes.
“It’s a great way to push out timely information, interact with individuals on a more informal level. You can use a more playful tone on blogs,” says Steinberg. JetBlue ‘crewmembers’ are encouraged to comment and participate. The blog’s Tuesday Travel Tips is provided by on-location employees. Participation is on a voluntary basis.
Employee privacy has not yet been a large issue with JetBlue. Issues are dealt with on a case-to-case basis, and crewmembers are encouraged to be honest and candid—but professional. If they are commenting on their work at JetBlue, they are asked to identify who they are and what they do. They must identify themselves as JetBlue employees. Transparency is important, and that is a big part of what BlueTales looks to offer.
Steinberg serves as the main moderator of BlueTales. All comments—customer- or employee-based—are screened by her before they are posted on the Blog. Defamatory or vulgar language is not approved of, but negative comments are generally allowed as long as they are not directed at a specific employee.
“You Can’t Make This Shtick Up,” the column where crewmembers are encouraged to tell interesting or funny stories about their time at JetBlue, is the one that can prove to be most controversial, as employees sometimes offer stories considered perhaps a bit ‘risqué’ or skirt the edge of what is considered professional. However, even those submissions are monitored on an individual basis and subject to approval by Steinberg. If an employee takes issue with content and feels he/she must voice this, the comment is allowed so long as it isn’t vulgar and doesn’t single out individuals.
“If there’s an issue, I contact the crewmember directly,” says Steinberg. Communications are private and direct, conducted via e-mail. They are also resolved as quickly as possible. When addressing issues of social media, the speed of the company response has become a key issue.
Tweaking the policy
One consensus that has been reached among companies is that a social media policy can’t be a static document. Many modifications are likely required given the rapidly evolving nature of social media. At Intel, JetBlue, and BestBuy, guidelines are subject to change.
“When we formed our social media policy, there were a lot of concerns. ‘Are we guiding people?’ ‘Is this cracking down?’ We’d like to say no,” says Bob Boerschel, associate legal counsel at Best Buy. “It’s more about empowering our employees than restricting them.” Boerschel believes a company has to look to employees when creating its social media policy.
Since the iPhone vs Evo controversy, Best Buy has looked to improve its approach in regard to issues of employee conduct online.
For the most part, its approach is built on trust. “We believe people are largely well-intended,” says Edmond. A good deal of Best Buy’s social media policy reflects that. Issues of misconduct are dealt with on a case-by-case basis. Since the iPhone vs. Evo controversy, the company has made moves to establish a peer-review system intended to address specific online concerns. Its purpose is to examine online incidents that might require disciplinary action, and determine what level of escalation would be required.
Issues are approached as they would be in an offline setting. Employees are expected to have their opinions, and they are expected to share those opinions with people outside of the company.
“Employees are friends with people,” says Edmond. “We don’t monitor these conversations. HR gets involved like it would with conversations in the break room.”
Social media has become a large part of Best Buy’s customer-friendly approach. The retailer has opened up forums for discussion on Facebook and Twitter, as well as its own website. Products and services are reviewed and rated by customers on a five-star basis. Employees are invited to participate. Their input on the Best Buy forums is identified by a yellow Best Buy tag.
“We encourage our employees to get out there and communicate, and we ask employees to blog about products,” says Boerschler.
Twelpforce, Best Buy’s Twitter and feed-based customer service center, is one of these policy-based outlets. A Twitter user can ‘tweet’ a question containing ‘@twelpforce’ within Twitter’s 140-word limit. Employees will view and respond to the question under the Twelpforce Twitter, with an extra @ mention tag identifying the number of the agent who has responded personally to the question. Answers that exceed Twitter’s 140-word character limit are directed to the Best Buy feed (http://www.bbyfeed.com/) in which the original conversation is re-posted along with an extended reply. It is visible to all users.
Participation in Twelpforce is voluntary. When creating a Twelpforce account, employees are prompted to agree to Best Buy’s social media guidelines as well as the company’s legal code of conduct. Employees are allowed to interact freely with customers on these outlets so long as they are clearly identified as Best Buy employees and adhere to the general code of conduct.
Questions are often answered in less than an hour. Twelpforce agents offer information and advice on an interactive level through a helpline or via in-person customer assistance. What is the main difference between assistance online and in-store assistance? On Twitter, a comment can be ‘retweeted’ to other users and instantly become viewable to thousands within hours.
This was the issue faced by Chrysler this past March. A contractor mistakenly released a defamatory tweet on Chrysler’s Twitter account. In addition to the account’s 7,400 followers, the message was retweeted to thousands more before Chrysler had it deleted and replaced with a public apology. The contractor was terminated, and Chrysler ended its relationship with the social media firm he had represented.
Best Buy’s ethics blog
Edmond was asked if Best Buy’s ethics office has seen more questions related to social media policy. Her answer: Yes and no.
Edmond runs Best Buy’s ethics column (www.kathleenedmond.com), a blog started in 2009. On the blog, she discusses ethical concerns confronted by Best Buy employees on a day-to-day basis. Names and numbers are removed, but the situations are real. Customers, as well as employees, are encouraged to participate and give their input on entries and the cases as they come up.
Edmond acts as moderator for comments received. In the past three years, she has encountered only a few instances where moderation was required. In one instance an employee, responding to one of her posts, accidentally gave out company numbers that should have been private. Edmond contacted the employee in question, informing him of the slip. The employee’s response was immediate, “Oh my god, I didn’t realize.” He requested to be allowed to edit out the offending information, and it was removed.
Edmond does not see online censorship as an issue when it comes to bloggers who choose to comment on the blog, whether they are outside visitors or employees: “The community monitors social media. I will not clean it up. You will see the raw form of it. The worst thing you can do is over-manage it.” She does, however, remove profanity and spam.
Edmond’s Ethics blog gets 17,000 unique views a month. The majority of views tracked come from outside of the company. “I’m blown away by the visibility it’s gotten.” Edmond was ranked 27th in the Ethisphere Institute’s most recent survey on ‘The Top 100 Most Influential People In Business Ethics.’ She has been cited as ‘one of the best examples of compliance officers who really engage with employees to further entrench the idea of ethical operations from the top down.’
Employees are most definitely engaged. Her stories regarding ethical issues encountered by Best Buy employees have proven a useful ‘learn from example’ tool within the company: “People use it for training. Managers come to me and say, ‘Gosh, I read your story six months ago and it really helped me resolve an issue I was having.’”
Interest in these cases extend to visitors from outside of the company as well: “Once a week I get a call from someone in the U.S., Canada, Mexico, telling me, ‘I love your blog, and I’d love to use it in our training materials.’”
Clearly, there is an upside to the evolving social media that a corporate social media policy must be careful to preserve. Is it about allowing freedom? “‘Allowing freedom’ is a term that really clanks for me,” says Edmond. “It’s more ‘just keeping up.’”
In the face of rapidly evolving modes of communication, an open policy toward social media has become a necessity, not a choice.
Alexandra Theodore is an assistant editor at Ethikos.