Anna Lawlor is director of Social i Media
COMPLYING WITH THE FCA
Things to consider:
• The content you post should be truly informative and relevant to the audience you have in mind. Draw on previous experience with clients – the typical questions they ask, the financial concerns they share – and base your original content on addressing these in broad, generic terms.
• Pick the right social media platform for the task: Twitter’s 140-character limit might make it better as an in-bound source (staying in touch with peers, events and industry news), while a longer blog, video or slide-share might be more suitable for more in-depth insights.
• Some financial services firms provide a link to an FCA disclaimer in the profile section of their social media accounts. This is not a fail-safe compliance tactic and has not been commented on by the FCA, but does show regulatory awareness in the use of social media. However, the content of the account must also reflect this.
• Any conversations on social media platforms that pose a potential regulatory breach, such as requests for specific advice, should be taken offline by offering a simple explanation of the regulatory parameters within which advisers deliver advice.
• Perform regular reviews of content on your social media platforms. Any out-of-date guidance, views or information should be removed or updated. Be aware that publicly-available content could be returned by a search engine and read out of the context you may have intended. This may be a key concern for the FCA.
• Be very aware of privacy settings. Anything posted to Twitter is automatically public and searchable, and publishing carries the same legal responsibilities as traditional publishing, such as copyright and defamation. Sites such as Facebook and LinkedIn offer a variety of public, private and hybrid (select group) sharing functions, so do not simply rely on default privacy settings.
• Use different secure passwords (formed of upper/lower case, numbers and signs) for each online account to make them more secure from hacking threats. A password manager such as LastPass auto-generates secure passwords and can securely store your range of passwords.
COMPLIANCE RESOURCES
http://www.asa.org.uk/
http://www.unbiased.co.uk/compliance-and-social-media
http://www.fca.org.uk/
http://www.cap.org.uk/Advice-Training-on-the-rules/Advice-Online-Database/Remit-Social-Media.aspx
