Drafting a social media policy for your practice, or reviewing the policy in place at your firm, can take away some of the angst you may feel when using social media, says Paula Hewitt, head of legal at Dundee Goodman Private Wealth.
“Advisors need to determine what their individual goals are with social media,” says Hewitt. “Do they want to communicate with current clients? Or do they want to be finding new prospects?” Whichever the response, there should be specific guidelines in your firm’s policy on how to approach these goals using social media platforms.
If your firm does not have an internal social media policy, or if you are working on an independent platform, establishing a policy for your practice could help to ensure that you’re approaching social media in an effective and compliant manner.
Hewitt suggests sitting down with the compliance department and/or a branch manager to discuss how a social media policy can help your individual business.
A social media policy should indicate the following:
Are you allowed?
A social media policy will first indicate whether or not your firm has permitted advisors to use social media for business purposes. The Mutual Fund Dealers Association of Canada (MFDA) suggests that firms that do not permit their reps to use social media should have specific policies outlining their position, and should ensure this stance is communicated to reps.
Personal vs. business use
Depending on how you are going to be using social media, you may or may not be subject to direct supervision by your firm. Guidelines from the Investment Industry Regulatory Organization of Canada (IIROC) specify a difference between personal use vs. business use on social media, and state that business use of social media is subject to supervision by your dealer.
“If you are using social media as a vehicle through which you want to reach out to clients or advertise to clients, the best approach to take is to consider everything you do to be business use,” says Sean Shore, manager, business conduct compliance at National Bank Financial Ltd.
You may want to reconsider having a separate personal social media profile if it could negatively affect your business practice. If you do decide to maintain a personal Twitter or Facebook profile, it is recommended that you assume that all of your activity on these platforms is subject to supervision. Even if you omit your job title and company name, clients could still find personal profiles during a Google search.
Advisors at Canaccord Genuity Corp. are permitted to use the big three social media platforms: Facebook, LinkedIn and Twitter. Although the firm does not prevent advisors from opening an account for personal use, its internal policy cautions that all social media usage should be representative of the advisor and his/her brand.
“We recommend that our advisors proceed with caution when they decide to open a personal page and that they act in a professional manner regardless if they are posting to a personal or business page,” says Paul Morosin, vice president, technology initiatives with Canaccord Genuity Wealth Management.
Platforms
Check your dealer’s social media policy to determine which platforms have been approved to use for business purposes. Although Facebook, Twitter and LinkedIn are the three most commonly used sites, other platforms could include YouTube, Pinterest, Instagram and individual blog sites.
“Dealers have finite resources to monitor and supervise social media platforms and it would not be practical to support all of them for business use,” says Shore.
Archiving
IIROC guidelines state that firms must be prepared to monitor advisors’ social media activity fully, as well as archive and store all communications that are conducted on social networking sites. Many firms have hired third party providers to ensure that all social media communications are captured and archived for regulatory purposes.
Some of these providers also offer additional social media tools for firms and advisors, such as content libraries, mobile apps and client listening tools, which monitor clients’ social media activity to help advisors identify selling opportunities.
Content
Depending on the type of content you are posting, there are different supervision requirements under IIROC’s guidelines. Advisors should be aware of the differences between static and interactive content, third party content and endorsements. (Learn more about the different types of content in the next article in this series.)