Hi! It’s Tory Haggerty from Tuscan Club University’s Fair Lending School and welcome to another Fair Lending Short.
In this Fair Lending Short I want to talk about a Social Media Policy. Now to be honest if you‘d asked me a few years ago, I would have probably said a Social Media Policy is not that big a deal.
Nowadays I feel like it could be one of the most important policies at your organization. Especially when you’re talking about Fair Lending. You should let every employee of your organization know what is acceptable social media use and what is acceptable social media behavior. And not just on your official organizations’ sites, but also on their own personal social media pages.
If your organization makes loans, you fall under the Equal Opportunity Act, probably the Fair Housing Act. There are a lot of laws and prohibited basis regulations that you must follow. If any employee of your organization makes racist or hateful comments online about any prohibited basis group, what does that say about your organization?
Employees may say, “But these are my own opinions, I didn’t list my employer.”
That doesn’t matter. If you are going to work in this highly regulated, highly sensitive environment, you have to make the sacrifice and often not voice your opinion on controversial issues. You want to give your employees the opportunities to understand that this is not acceptable behavior on your personal social media pages, and this is the cost of entry to work in this industry. If you don’t spell this out, how can you hold them accountable? Lastly, you should probably have them read and attest to the social media policy. Not just when their employment starts, but on an annual basis.
How many of you read your organization’s Social Media Policy eight years ago when you started and haven’t seen it since? This is one of these things you should do every year when you do your annual training. Have them read through the company’s Social Media Policy, sign, and attest to it. Otherwise, how do you hold them accountable if they haven’t read your policy in the last ten years?
Thanks for reading!