Social Media Policy

Wave Community Bank 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.

The processing of your personal data. Those circumstances are:

• you contest the accuracy of the personal data;
• processing is unlawful but you oppose erasure;
• we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and
• you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.

 We will only otherwise process it:

• with your consent;
• for the establishment, exercise or defence of legal claims; or
• for the protection of the rights of another natural or legal person;

The right to object to processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the data is necessary for the purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

The right to data portability
To the extent that the legal basis for our processing of your personal data is:

1. consent; or
2. that the processing is necessary for the performance of our contract with you

You have the right to receive your personal data from us in a commonly used and machine-readable format or instruct us to send this data to another organisation. This right does not apply where it would adversely affect the rights and freedoms of others.

Rights related to automatic processing
This credit union uses an automated decision making process for processing members’ loan applications to make sure that our decisions are quick, fair, efficient, and correct based on what we know.

The automated lending decision system looks at your credit score alongside information such as:

• the amount applied for
• your income and expenditure
• your history of repaying debts
• the number and value of County Court Judgements (CCJs) you have
• the number of accounts you have that are in default
• public information such as the insolvency service
• whether or not you are bankrupt
• your age
• and makes a decision based on either
• Set policies e.g. the credit union does not lend to those less than 18 years of age, or the credit union does not lend to people with over a certain value of county court judgements.
• The predicted likelihood of the repayment of the loan based on the statistical analysis of whether individuals who had a similar credit profile repaid their debts in the past.

Members have the right to have the decision reviewed by a member of staff, express their point of view, and obtain an explanation of the decision and challenge it.

Right to withdraw consent
To the extent that the legal basis for our processing of your personal information is your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

The right to complain to the Information Commissioner’s Office
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner’s Office which is responsible for data protection in the UK. You can contact them by:

1. Going to their website at: https://ico.org.uk
2. Phone on 0303 123 1113
3. Post to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Contact us about your rights
For more information about how your rights apply to your membership of the credit union or to make a request under your rights you can contact the Operations Manager at info@wavecb.org.uk or 0300 303 3188. We will aim to respond to your request or query within one month or provide an explanation of the reason for our delay.

You can send a subject access request or a right to be forgotten request to:

By Post : Wave Community Bank, Tisbury Road Offices, Hove Town Hall, Tisbury Road, Hove BN3 3BQ
By Phone: 0300 3033188
Email: info@wavecb.org.uk

Or in person at our office and help points

Contact details of credit union

Name: Wave Community Bank
Address: Tisbury Road Offices, Hove Town Hall, Tisbury Road, Hove BN3 3BQ
Phone: 0300 3033188
Email: info@wavecb.org.uk

Changes to this Policy
We can update this Policy at any time and ideally you should check it regularly here for updates. We won’t alert you for every small change, but if there are any important changes to the Policy or how we use your information we will let you know and where appropriate ask for your consent.