Social Media and Personal Device Use: Policy Essentials

Social Media and Personal Device Use: Policy Essentials

In an era where communication is instantaneous and devices are constantly connected, firms must take a proactive approach to managing the risks associated with social media and personal device use. For investment advisers, these risks are not just reputational—they can also lead to serious compliance violations. This blog outlines the essential elements of an effective policy governing employee use of social media and personal devices.

1. Define Permitted and Prohibited Activities

Clear boundaries must be set regarding what employees can and cannot do on social media and personal devices. Policies should:

         • Prohibit business communications on unmonitored personal apps or platforms.

         • Specify approved communication tools for client interactions.

         • Restrict use of social media for marketing or promotional purposes without pre-approval.

2. Recordkeeping and Monitoring Requirements

Regulators require that all business-related communications be captured and retained, regardless of the platform used. Firms should:

         • Implement tools that monitor and archive messages across approved devices and platforms.

         • Ensure employees understand that personal devices used for business must comply with firm policies.

         • Regularly audit communications for unauthorized use or compliance gaps.

3. Employee Training and Attestations

Policies are only effective if employees understand and acknowledge them. Best practices include:

         • Providing training on acceptable use of social media and personal devices.

         • Requiring annual attestation to the firm’s communication policies.

         • Reinforcing expectations through periodic updates and reminders.

4. Enforcement and Disciplinary Measures

To be taken seriously, policies must include clear consequences for violations. Advisers should:

         • Establish a tiered system of disciplinary action for noncompliance.

         • Document all violations and follow-up actions.

         • Apply enforcement consistently across all employees and roles.

5. Policy Review and Updates

The digital landscape evolves quickly. Firms must ensure their policies remain current by:

         • Reviewing policies at least annually or when new platforms emerge.

         • Soliciting feedback from compliance and IT teams.

         • Updating protocols in response to regulatory guidance and enforcement trends.

Conclusion

A strong policy on social media and personal device use is critical to maintaining compliance and protecting your firm’s reputation. By establishing clear expectations, monitoring appropriately, and keeping policies up to date, firms can reduce risk while enabling safe and responsible use of modern communication tools.