There’s usually one in every company. The cowboy. He’s got a swagger in his walk and a smirk in his talk. He gives lip-service to the rules because he’s smarter than the rest of us. He’s too full of testosterone or maybe a deep-seated desire to get daddy’s attention. Who knows what really motivates him?
If you’ve got one in your company, don’t authorize him to use social media. Don’t let the cowboy shoot your firm in the foot.
There’s also his gender equivalent, the cowgirl, who usually manifests as Calamity Jane. No one knows her real motivation until it’s too late.
They may have supervisory deficiencies, letters of admonition, censures, or fines. They’re on the radar of the compliance office—not to mention the regulators.
In last week’s LIMRA webinar, FINRA’s Director of Programs & Investigations, Advertising Regulation, Amy Sochard said,“If someone is deemed unreliable, do you want to stake your brand and reputation on that person?”
In a February 3, 2010 FINRA webinar, she put it more directly: “Problem representatives who are on heightened supervision should not be permitted to use social media.”
Especially because social media gives you the opportunity to screw up on a grand scale.
When I ran media relations for NASDAQ, then later NYSE Regulation, I would tell my staff that what we did was like walking through a mine field. On any given day, through an unguarded comment or lapse in judgment, we could blow ourselves right out of
our jobs. Now, through the power of social media, everyone runs the same risk.
Staffers barred from using the firm’s social media platforms must also understand that they cannot perform company business over their personal social media accounts.
Educate and train employees whose judgment you do trust about your social media policy. Archive their communications. Supervise them. Have an in-house disciplinary system in place if serious mistakes are made and use it. Regulators demand it.
But don’t allow the company cowboy to tweet.
By Scott Peterson, Co-Founder, Relay Station Social Media LLC
