Social Media and Bank Compliance/Security

January 16th, 2018 by James Atkinson

Growing up in a small town in South Carolina, little did I know that in my days of childhood, we were into social media, cutting edge and ahead of our time we were! Only our social media was the small county weekly newspaper. Elderly ladies from each of the little towns and communities would write articles telling who visited who last Sunday and who ate what for Sunday lunch – "...his wife and two sons visited his mother, went to church, and afterwards they had fried chicken, corn, okra, string beans, and apple cobbler and ice cream".

Today social media takes on a very different role – any form of electronic communication through which users share information, ideas, personal messages, and other content. We know all the forms of social media. We hear about them constantly and many of us use them constantly, but have we thought about and included in our financial institution policies what we need to in terms of mitigating the associated risks of social media? Are we aware of the need to use social media to our advantage and for compliance as a financial institution?

Our advertising policy should include social media. Thus, only advertising personnel in conjunction with review and approval of the Compliance Department should be creating social media content that qualifies as advertising. A mortgage lender should not be posting "Come see me at National Bank to get your mortgage loan". That is advertising.

Social media institution customer feedback/comments should be monitored and tracked as part of the customer complaint tracking process.

Bank policy should prohibit transmission of confidential, security, privacy and proprietary information though social media. Think of the potential security risks presented by an employee posting "I hate Wednesdays from 2 to 3 when I am the only lobby employee and everyone else is in the back or having lunch" or "I wish they would quit changing that all clear signal each morning". How about privacy considerations by "I can't stand that customer Mr. Smith who comes to my window first thing every morning to get $1000 in 20's from his account for his store. He is so rude".

Well, be it in terms of policies, compliance, or just monitoring for information, don't forget about social media. There is a lot more to social media today than last Sunday's visitations and lunch.