Social Media Policy

Social Media Policy

STATED OBJECTIVE

It is the policy of Wave Community Bank (“WCB”) to engage and utilize social media as may be appropriate in its marketing and communications strategies. For the purpose of this policy, social media is inclusive of any form of interactive online communication, in which users can generate and share content through text, images, audio, and/or video, including but not limited to:

Micro-blogging sites (e.g. Facebook, Google Plus, Instagram, and Twitter);
Forums, blogs, customer review web sites and bulletin boards
Photo and video sites (e.g. YouTube);
Sites that enable professional networking (e.g., LinkedIn)
Virtual worlds (e.g., Second Life);
Social games (e.g., FarmVille and CityVille);
Any other formats of electronic communication that gain sufficient popularity.

WCB recognizes the added value of leveraging social media in communicating with its members and non-members. Being active in social media networking allows WCB to be current and relevant while leveraging low-cost marketing tools. Social media is about building a community of supporters; it provides an opportunity to share and further WCB’s objectives and mission to provide quality financial products and services and to promote member education with respect to financial products and services.

STATEMENT OF PURPOSE

WCB recognizes there are certain inherent risks with respect to social media regardless of WCB’s active participation in it. Social media poses additional legal, compliance, financial, reputational and operational risk. Therefore, the Board has approved this Social Media Policy to facilitate both directives and guidance to WCB’s employees and directors (collectively, “employees”) to mitigate such risk.

RESPONSIBILITY OF POLICY

The primary responsibility for ensuring compliance with this policy and its operating procedures rests with senior management and each employee. Any material change to this policy must be approved by the Board of Directors. The Board shall also review and approve this policy where applicable for any changes that may be necessary to ensure WCB’s compliance and for risk mitigation. Senior Management is responsible for ensuring appropriate directives are implemented and administered in compliance with this approved policy. Any violation of this policy must be promptly reported to the Business Development Manager.

COMPLIANCE AND LEGAL RISKS

Compliance and legal risk arise from the potential for violations of, or nonconformance with, laws, rules, regulations, prescribed practices, internal policies and procedures, or ethical standards. These risks also arise in situations in which WCB’s policies and procedures governing certain products or activities may not have kept pace with changes in the marketplace. This is particularly pertinent to an emerging medium like social media.

Further, the potential for defamation or libel risk exists where there is broad distribution of information exchanges. Failure to adequately address these risks can expose WCB to enforcement actions and/or civil lawsuits. If WCB deems it necessary to engage in social media to market products and originate new accounts, WCB will take appropriate steps to ensure that advertising, account origination, and document retention are performed in compliance with applicable consumer protection and compliance laws and regulations.

REPUTATION RISK

Reputation risk is the risk arising from negative public opinion. Activities that result in dissatisfied consumers and/or negative publicity could harm the reputation and standing of WCB, even if WCB has not violated any law. WCB’s media activities will be sensitive to, and properly manage, any reputational risk that arises from those activities, including;

Fraud and Brand Identity
Third Party Concerns
Privacy Concerns
Consumer Complaints and Enquiries
Employee Use of Social Media Sites.

OPERATIONAL RISK

Operational risk is the risk of loss resulting from inadequate or failed processes, people, or systems. The root cause can be either internal or external events. Operational risk includes the risks posed by WCB’s use of information technology (IT), which encompasses social media. Social media is one of several platforms vulnerable to account takeover and the distribution of malware. WCB will ensure it implements controls to protect its systems and safeguard customer information from malicious software, adequately address social media usage, including its Data Breach Procedure as appropriate.

SOCIAL MEDIA RISK MANAGEMENT & TRAINING

It is the policy of WCB to implement and maintain risk management processes and training that allows WCB to identify, measure, monitor, and control the risks related to social media. These shall be adequate relative to the extensiveness of WCB’s involvement in this medium.

In the event WCB chooses not to use social media through certain mediums, WCB will still be prepared to address the potential for negative comments or complaints that may arise within the many social media platforms and provide guidance for employee use of social media.

The risk management & training will include the following to the extent applicable and as reasonably feasible:

Policies and/or procedures (either stand-alone or incorporated into other policies and/or procedures) regarding the use and monitoring of social media and compliance with all applicable consumer protection laws, regulations, and guidance. Further, policies and procedures should incorporate methodologies to address risks from online postings, edits, replies, and retention
A due diligence process for selecting and managing third-party service provider relationships in connection with social media
An employee training program that incorporates WCB’s policies and/or procedures for official, work-related use of social media, and potentially for other uses of social media, including defining impermissible activities
An oversight process for monitoring information posted to proprietary social media sites administered by WCB or a contracted third party
Audit and compliance functions to ensure ongoing compliance with internal policies and all applicable laws, regulations, and guidance
Parameters for providing appropriate reporting to the Institution’s senior management that enable periodic evaluation of the effectiveness of the social media program and whether the program is achieving its stated objectives.

SOCIAL MEDIA COORDINATOR APPOINTMENT

The Board appoints the Business Development Manager to engage in the use of social media on behalf of WCB. The Business Development Manager is responsible for engaging staff as may be necessary to develop the appropriate content to be posted. The Business Development Manager is authorized to designate an alternative in the event of absence or as may otherwise be essential to complete the duties required.

Furthermore, it is the policy of WCB that the Business Development Team shall continually explore methods of electronic communication and determine which of them can be useful and cost effective in its marketing strategy. It shall then devise programs for the utilization of the electronic communication channels that it selects.

The Business Development Committee shall have the authority to approve the use of new social media communication channels and proprietary sites, upon the recommendation of the Business Development Manager, after thorough due diligence, including a risk assessment.

The Business Development Manager is authorized to evaluate any negative information posted on social media regarding WCB, and to make the final determination as to how to respond. Authorized responses are limited to posting positive information about WCB, answering questions about WCB with factual unbiased information, or taking legal or procedural action to remove content, in consultation with the Board.

USE OF SOCIAL MEDIA

Authorized employees may engage in social media activity during work time provided that such activity is directly related to their work and does not interfere with their or their co-workers’ work. In the event of comments posted by members or non-members regarding WCB, all such comments will be addressed proactively and timely. Any complaints shall be addressed in accordance with WCB’s Complaints Policy and shall be elevated to the appropriate line of business where applicable, up to and including Risk Management. The Business Development Manager is responsible for ensuring appropriate and timely responses are provided in accordance with the Complaints Policy.

COPYRIGHT AND INTELLECTUAL PROPERTY

Infringement on any party’s copyright, patent, trademark, trade secret, intellectual property, or other proprietary rights, or right of publicity or privacy is strictly prohibited and is the user’s sole responsibility. By submitting any content to WCB’s Facebook page, users warrant and represent that they are the copyright owner of the content or that the copyright owner of the content has granted permission to use such content consistent with the manner and purpose of their use. Using WCB’s Facebook page to distribute unauthorized copies of copyrighted material, including photos, artwork, text, recordings, designs, computer programs or derivative works of such programs is strictly prohibited and subject to removal.

Please note that by posting comments, posts, tagged photos, videos, ideas, or any other content on our Facebook page, users are granting WCB nonexclusive, worldwide rights to republish, redistribute, or otherwise use this content in perpetuity in any way we see fit. This includes, but is not limited to, marketing and advertising materials.

PRIVACY AND SECURITY

With respect to content collected through WCB’s Facebook page, WCB follows Facebook’s privacy policy. Please note that when visiting any official WCB Facebook page, users are also subject to the terms and conditions of WCB’s privacy policy and general terms of use, as well as Facebook’s terms of service and privacy policy. To protect users’ privacy and the privacy of others, please do not include personally identifiable information such as National Insurance numbers, account numbers, phone numbers or e-mail addresses in any comment or post. If users do include personally identifiable information in a comment, this comment or post may be deleted.

Third Party Content Disclaimer – Facebook

WCB from time to time makes information of third parties available on WCB’s Facebook page (the “Third Party Content”). The Third Party Content is provided for general informational purposes only and WCB’s posting of the Third Party Content does not constitute an endorsement or recommendation of such Third Party Content.

REPORTING AND MONITORING

The Business Development Team will monitor websites, blogs, forums, news, social media sites and bulletin boards for defamatory and malicious discussion or comments, rumours or inaccuracies as well as positive discussion, including comments referencing brand abuse and/or identity theft leveraging search tools such as Google Alerts and search features on common sites such as Facebook, Twitter, Google, LinkedIn, and such others as may be appropriate. Due to the fast pace of social media, relevant posts and quick responses are a requirement.

Therefore the Business Development Manager will be notified of all WCB mentions that require immediate action and engage the necessary staff to mitigate, sustain and/or terminate any references made regarding WCB that may cause harm to WCB’s reputation, brand, members and/or employees.

The Business Development Manager will report to the Business Development Committee on the effectiveness of WCB’s social media program and whether the program is achieving its stated objectives.

TRAINING

The Business Development Manager shall ensure appropriate social media training is provided to new and existing employees.

RECORD RETENTION

WCB shall retain when feasible, evidence of compliance with this policy in accordance with the applicable regulations.