Social Media Policy – Trust is a must

Social Media Policy

At DBA, Inc. hereunto referred to as DBA, we understand that social media can be a fun and rewarding way to share your life and opinions with family, friends and co-workers around the world. However, use of social media also presents certain risks and carries with it certain responsibilities. To assist you in making responsible decisions about your use of social media, we have established these guidelines for appropriate use of social media.

This policy applies to all associates who work for DBA.


In the rapidly expanding world of electronic communication, social media can mean many things. Social media includes all means of communicating or posting information or content of any sort on the Internet, including to your own or someone else’s web log or blog, journal or diary, personal web site, social networking or affinity web site, web bulletin board or a chat room, whether or not associated or affiliated with DBA, as well as any other form of electronic communication.

The same principles and guidelines found in DBA policies and three basic beliefs apply to your activities online. Ultimately, you are solely responsible for what you post online. Before creating online content, consider some of the risks and rewards that are involved. Keep in mind that any of your conduct that adversely affects your job performance, the performance of fellow associates or otherwise adversely affects members, customers, suppliers, people who work on behalf of DBA or DBA’s legitimate business interests may result in disciplinary action up to and including termination.

Know and follow the rules

Carefully read these guidelines, inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject you to disciplinary action up to and including termination.

Be respectful

Always be fair and courteous to fellow associates, customers, members, suppliers or people who work on behalf of DBA. Also, keep in mind that you are more likely to resolve work related complaints by speaking directly with your co-workers or by utilizing our Open Door Policy than by posting complaints to a social media outlet. Nevertheless, if you decide to post complaints or criticism, avoid using statements, photographs, video or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage customers, members, associates or suppliers, or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of race, sex, disability, religion or any other status protected by law or company policy.

Be honest and accurate

Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts you have altered. Remember that the Internet archives almost everything; therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false about DBA, fellow associates, members, customers, suppliers, and people working on behalf of DBA or competitors.

Post only appropriate and respectful content

Maintain the confidentiality of DBA trade secrets and private or confidential information. Trades secrets may include information regarding the development of systems, processes, products, know-how and technology. Do not post internal reports, policies, procedures or other internal business-related confidential communications.

Respect financial disclosure laws. Such online conduct may also violate the Insider Trading Policy. Do not create a link from your blog, website or other social networking site to a DBA website without identifying yourself as a DBA associate.

Express only your personal opinions. Never represent yourself as a spokesperson for DBA.  If DBA is a subject of the content you are creating, be clear and open about the fact that you are an associate and make it clear that your views do not represent those of DBA, fellow associates, members, customers, suppliers or people working on behalf of DBA. If you do publish a blog or post online related to the work you do or subjects associated with DBA, make it clear that you are not speaking on behalf of DBA. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of DBA.”

Using social media at work

Refrain from using social media while on work time or on equipment we provide, unless it is work-related as authorized by your manager or consistent with the Company Equipment Policy. Do not use DBA email addresses to register on social networks, blogs or other online tools utilized for personal use.

Retaliation is prohibited

DBA prohibits taking negative action against any associate for reporting a possible deviation from this policy or for cooperating in an investigation. Any associate who retaliates against another associate for reporting a possible deviation from this policy or for cooperating in an investigation will be subject to disciplinary action, up to and including termination.

Media contacts

Associates should not speak to the media on DBA behalf without contacting the owners directly. All media inquiries should be directed to them.

Communicating via Social Media Outlets: 

When communicating via social media on behalf of our company or on topics related to the business of our company, employees will:

  1. Disclose who we are, who we work for, and any other relevant affiliations from the very first encounter.
  2. Ensure that all disclosure meets the minimum legal standard by being a) clear and conspicuous, b) understandable by the average reader, and c) clearly visible within the relevant content.
  3. Require all employees to disclose their employer when using social media to communicate on behalf of the company or about company-related topics.
  4. Make certain that disclosure is sufficient so that the average reader understands that our company is responsible for the content, while they are reading the content.
  5. Pseudonyms:  Never use a false or obscured identity or pseudonym.   If aliases or role accounts are used for employee privacy, security, or other business reasons, these identities will clearly indicate the organization represented and provide means for two-way communications with that alias.
  6. Provide a means of communicating with our company in order to verify our involvement in a particular item of social media content.
  7. Instruct all employees, agencies, and advocates with whom we have a formal relationship on these disclosure policies and require them to comply.

For personal blogs or social media interactions:

  1. If employees write anything related to the business of their employer on personal pages, posts, and comments, they will clearly identify their business affiliation.
  2. The manner of disclosure can be flexible as long as it is a) clear and conspicuous, b) understandable by the average reader, and c) clearly visible within the relevant content. (Example disclosure methods could include: usernames that include the company name, or a statement in the post or comment itself, “I work for ____ and this is my personal opinion.”)
  3. Employees will specifically clarify which post or comments are their own opinions vs. official corporate statements.
  4. Writing which does not mention work-related topics does not need to mention the employment relationship.
  5. If employees post or comment anonymously, they should not discuss matters related to the business of their employer. If employer-related topics are mentioned, they should disclose their affiliation with the company.

When communicating to the social media community on behalf of our company, we will:

  1. Comply with all laws and regulations regarding disclosure of identity.
  2. Disclose who we are, who we work for, and any other relevant affiliations from the very first encounter.
  3. Proactively ask the recipient of the outreach to be transparent and fully disclose their relationship and communications with our company.
  4. Instruct them on the importance of disclosure and ask them to meet or exceed our disclosure guidelines.
  5. Never use off-topic or misplaced posts, comments, or tags for promotional intent.
  6. Never take action contrary to the specific boundaries, terms and conditions, and community guidelines set by each site, social network, or community.
  7. Not use services or technologies for mass-posting comments.
  8. Use extreme care when communicating with minors or using social networks intended for minors.
  9. Contractually guarantee that any third-party outreach program we participate in meets or exceeds our internal standards.

When communicating via social media, or asking others to communicate via social media on our behalf, we will:

  1. Always be truthful.
  2. Ensure that information and claims provided to advocates, consumers, and social media sites are factual, honest, and accurate.
  3. Never ask someone else to deceive readers for us.
  4. Never ask advocates to write something they do not believe.
  5. Never ask advocates to endorse a product they have not used personally or create any other form of false endorsement.
  6. Insist that all opinions shared with the public express the honest and authentic opinion of the consumer or advocate without manipulation or falsification.
  7. Ensure that all individuals who are speaking for us are free to form their own opinions and share all feedback, including negative feedback.
  8. It’s good business practice for companies (and individuals) to keep certain topics confidential. Respect confidentiality. Keep topics focused to matters of public record when speaking about the company.  Do not disclose non-public company information or the personal information of others such as co-workers, customers, or vendors.
  9. Treat past and present co-workers other personnel, suppliers, consumers, partners, competitors, and yourself with respect. Avoid posting materials or comments that may be seen as offensive, demeaning, inappropriate, threatening, or abusive. Acknowledge differences of opinion. Respectfully withdraw from discussion that go off topic or become profane.
  10. Consider everything you post to the Internet the same as anything you would post to a physical bulletin board or submit to a newspaper. Many eyes may fall upon your words, including those of the press, consumers, and competitors. Assume that all of these people will be reading every post, no matter how obscure or secure the site to which you are posting may seem.
  11. Follow all applicable section of the DBA, Inc., Employee Manual specifically with regard to: Employment Policies, Confidential Information, Customer Relations, Harassment, Knowledge of DBA, Inc., Standards of Conduct, and Unacceptable Activities.

In order to correctly monitor our social media outreach for disclosure and factual errors, we will:

  1. Monitor the statements by our advocates that result from our communications and programs.
  2. Attempt to correct any misrepresentations or inaccurate statements that result from our outreach.
  3. Attempt to correct any missing disclosure by our advocates or representatives.
  4. Keep a record of all attempts to correct errors.
  5. Discontinue any relationship with an advocate or representative who repeatedly fails to meet disclosure or truthfulness requirements.
  6. Set a policy that “we didn’t know” is not acceptable at our company.

We will:

  1. Maintain and enforce a formal social media policy.
  2. Train all employees who use social media as a part of their jobs.
  3. Train employees about appropriate use of social media not directly related to their jobs.
  4. Educate employees about when personal use of social media requires disclosure.
  5. Track employee use of social media for activity that violates our social media policy.
  6. Make social media training a part of our standard HR procedure.

To follow the spirit of our policy, we will:

  1. Err on the side of over-disclosure. If a reader would be surprised to discover a fact later, we will disclose it up front.
  2. Use the space available for improved disclosure. When space is limited (such as on Twitter), disclosure may be minimal, but for media with no space limits (such as on blogs, Facebook, or comments on other forums) we will provide complete disclosure in the comment.
  3. Make certain that all disclosure is sufficient so that the average reader clearly understands that our company is responsible for the content we initiate, while they are reading the content.
  4. Ask: Would we be uncomfortable if our family and friends read our posts in 20 years?
  5. Remember: Nothing is ever truly deleted from the internet, the internet never forgets.
  6. Check your facts and your emotions before you hit enter.
  7. Remember there are people reading your posts, not computers.
  8. Be kind, be engaging, be human.

“5 Rs of social media:

  1. Reason. Simply put: use reasonable etiquette, the same as you would offline.
  2. Represent yourself. Anonymous profiles lend themselves to more negative content.
  3. Responsibility. Make sure that what you’re saying is factually correct, and also that it doesn’t violate any legal guidelines that prohibit revealing information that is material to the company.
  4. Respect. What you say online is a permanent record, so don’t say anything online you wouldn’t feel comfortable saying to the whole place – with a camera rolling.
  5. Restraint. Before you hit that send button, pause and reread. If you wouldn’t want that particular thought or contribution forever associated with your name, don’t post it.

Adapted from:  Social, Disclosure Best Practices Toolkit and the website for the National Labor Relations Board, a template for Social Media Policies.