3 Lessons From Lady Gaga's $9 Billion Twitter Hack

"Gaga, oh la la..."  Offering an iPad2 to each of her Twitter followers -- ah, sorry, "monsters" (her term of endearment for her adoring fans)...Let's see (pulling up the calculator app), that's a tidy sum exceeding $9 billion dollars to keep a hacker's promise of an iPad2 to each of Lady Gaga's 17,113,943 Twitter followers.  (No similar offer/hack was made on her Facebook page where she boasts   45,775,157 "monsters"!)

Joining the ranks of U.S. President Barrack Obama and Britney Spears, Lady Gaga found her Twitter account hacked, repeatedly offering an iPad 2 to her followers.  Even a bit much for a super-rich social media superstar who was the first to hit one billion YouTube views.

I spotted the story when TechCrunch first tweeted about it, less than an hour into the hack.  I immediately started tracking Lady Gaga's Twitter account to see how the communications crisis would unfold.  There was a running battle of the iPad offer appearing, being deleted, and reappearing.

With no message interjected from her Twitter account during the pitch of battle explaining what was happening, viewers were left to puzzle over what was really going on, though some math would have made it more likely than not that it was a hack, given the $9 billion dollar pricetag.  (No, I didn't click on the tempting link as I feared my own adoring Twitter fans...ok, friends...would soon be receiving a promise of a free iPad2.)

After about two hours, the running battle ended with Lady Gaga emerging victorious:


The tweets from her account that followed this announcement  were her typical tweets.

3 Lessons In Crisis Communications
From Lady Gaga

1.  Plan for Your Social Media Account To Be Hacked

"Wait, I'm not a superstar.  I'm just running a small business and trying to be social."  It doesn't matter.  Scores of social media accounts are hacked every day.  Some hacks happen because someone trustingly taps a malicious link.  Others happen because someone knows how to do it and you're their unfortunate victim.  Others happen because one of the apps you use is "leaky". Plan on being hacked and what you'll do when it happens.  (Having a secondary account already set up is a good way to start correcting the facts while you struggle with the task of wrestling back your account.)

2.  Pay Attention to Your Social Media Accounts

Social media is 24/7, viral and real-time.  If someone has hacked your account, you need to stop the bleeding as quickly as possible, as NBC News learned when its Twitter account was hacked and the account messaged a false report of a new attack on Ground Zero.  In the case of NBC, the account was taken down within ten minutes.  In Lady Gaga's case, the battle raged for about two hours. 

If you can, have more than one person monitoring your account.  Know that social network monitoring needs to continue even after 5:00 p.m. and on the weekends and holidays.  You owe it to your customers, "monsters", and to your brand.  It's the price of social business.

3.  Tell People What Happened, Where It Happened -- and Return to Business

For Lady Gaga, the return to business took place in a measured way, with a tweet announcing the hack was over, then two quick tweets about her normal routine and her appreciation for her fans...I mean, "monsters".

Don't ignore a social network hack or other communications crisis on your social network account.  Let your customers know you ran into a problem, what the problem was, and that the problem's been fixed -- then return to your normal routine.  (Yes, an apology is always good idea, too.)

If you can, communicate during the crisis what is taking place.  Stay calm.  Return to your routine after you've cleaned up any mess and offered the appropriate apologies or explanations.

What might you have done differently?  

Related Posts 

6 Lessons From Red Cross Beer Tweet  

How NOT to Use Hashtags & RTs in a Crisis

And please feel free to join me and my "monsters" on Twitter!  @GlenGilmore

A Social Media Reminder from the #NEearthquake #smem

"[T]ime for the E Coast to realize a 5.8 isn't a real earthquake." I was lectured on Twitter.  No doubt.

Everything is always a matter of perspective.  I had nothing to judge it by, but to me it seemed impressive.  I felt a deep sway.  I thought I might have gotten dizzy for some reason.  I stepped outside to see if a tree had fallen on my roof. 

I then returned to my desk and checked Twitter:  the north eastern U.S. had had an earthquake.  It rattled nerves more than anything else.

Still, it is a moment to reflect.  And I must confess, it impressed the heck out of me -- and I'm not easily impressed.

I naturally thought to call my family.  For about a half hour, though, the phones shared a simple message:  "All circuits are busy."  "So just send a text," another person on Twitter lectured.  Fine.  But what if I needed to make a 9-1-1 call.  "Ah, well...Welcome to our world!"

Let's begin planning for a "real" disaster - and optimizing social media

There are tales of police departments using social media to fight flash mobs and to track criminals.  Yet, for some reason, there are far fewer examples of social media being used to listen for and respond to basic emergencies.  "Well, that's what 9-`1-1 is for," I can already hear my detractors say.  But what happens, as happened in the north eastern U.S., today, when an earthquake strikes and all the phones are overloaded and 9-1-1 can't be contacted?  I know, I know, "it wasn't a real earthquake."  But that's my point, what if had been - one accompanied by massive death, injuries, destruction - and "all circuits busy."

We should be thinking now, more, about how we might put social media to work.  Connections already exist.  Numerous police departments and other local responders have Twitter accounts and Facebook pages.  It's time that they have training and policies to make social media emergency management as effective a tool as it possibly can be.

Don't get me wrong, I know how much is already being done in the field of social media emergency management.  Just search #smem on Twitter and you'll find an abundance of innovators and innovation, including FEMA.  All well and good, but we can and should do more.  Training.  Policies. 

If  I sound slightly alarmist, I hope that you will excuse me.  We are products of our past.

Related readings:

"Twitter 911" - A Proposal

10 Reasons Social Media Is Important in a Real Crisis

Social Media & Emergency Response Lessons from a Pioneer

Please join me on Twitter:  @GlenGilmore and @CrisisSocMedia

Please share your comments and ideas!  Thank you!

10 Commandments of Social Media for Financial Services

FINRA and the Existing Social Media Guidelines, 10-06

In January of 2010, the Financial Services National Regulatory Authority (FINRA), "the largest independent regulator for all securities firms doing business in the United States," issued Regulatory Notice 10-06, a set of ten social media guidelines for financial firms and their registered representatives, in Question and Answer form, recognizing that "Americans are increasingly using social media."

New Social Media Guidelines Coming,
But 10-06 to Remain Unchanged

More recently, on June 28, 2011, at the IRI Government, Legal and Regulatory Conference, in Washington, D.C., Richard G. Ketchum, Chairman and Chief Executive Officer of FINRA, issued a statement that FINRA's "goal is to provide further guidance on these issues in a Notice to be published later this year."
Importantly, however, in all the statements addressing the forthcoming additional guidelines, FINRA representatives have emphasized that any new guidelines will supplement rather than change the social media guidelines presented in Regulatory Notice 10-06.  This news, coupled with the the announcement of Morgan Stanley  that its nearly 18,000 financial advisers will be tweeting on Twitter and posting on LinkedIn before the year is out, has awakened a new interest in the use of social media within the Financial Services sector.

The 10 Commandments of Social Media
for Financial Services Slideshare

To help financial services firms, broker-dealers and their registered representatives better understand the opportunities and obligations of Regulatory Notice 10-06, the 10 Commandments of Social Media for Financial Services Slideshare has been prepared to review the guidelines that are expressly to remain core principles for social media engagement by the financial services.

For more information relating to Social Media for Financial Services, please follow: @FinancialSM

Related posts:



How have the existing Rules worked and what new guidelines are needed to give the Financial Services the latitude it needs to engage in new media?  Please share your comments.


Companies Using Social Media Get More Customers & Revenue #ROI

Still wondering if social media is a worthwhile venture for your business?  According to a newly-released survey of over 17,000 businesses world-wide, conducted by Regus, figures confirm, with rare exception, that those businesses that invest in social media see a measurable return on their investment, both in terms of new customers and increased revenues.



According to the survey's analysts, the results show that "a good blog is now no longer a pleasant addition [to a business' marketing presence], but a core skill and savvy use of Twitter and Foursquare, for example, can be real differentiators for a business."

For more social media news, please join me on Twitter:  GlenGilmore

Twitter & #FB Beat #LinkedIn In Daily Love




The numbers are in:  LinkedIn doesn't get much daily love compared to Facebook and Twitter.  "52% of Facebook users and 33% of Twitter users engage with the platform daily, while only 7% of MySpace users and 6% of LinkedIn users do the same," according to figures presented in a newly-released Pew study.  These figures say much about some key differences in the triumvirate of social networks:  Facebook, Twitter, and LinkedIn. 

Facebook and Twitter soundly trump LinkedIn for daily engagement.  This should give pause to some who still persist in thinking that LinkedIn is the only social network they need to be on to stay abreast of trends and topics related to their fields.  The most vibrant conversation is clearly taking place on Facebook and Twitter, as demonstrated by a much higher level of daily engagement than found on LinkedIn.  (Yes, there's plenty of chatter on all social networks, but, by engaging, you'll learn how to sift for the conversation gold.)


Please feel free to join me on LinkedIn  Facebook Twitter

Please comment below to let me know what you think about the stats and what they mean!  Thanks! 



Twitter Best Practices For Business

Twitter is a great place to do business, if you follow some simple best practices.  Twitter has done a nice job of outlining core advice on the subject in their welcome center:

For more great info on best practices for businesses on Twitter, be sure to visit Twitter's resource center for business!   Before go, though, please join me on Twitter!  @GlenGilmore


Women & 18-22 Year-Olds Most Likey to "Like" Facebook Content

In its latest study on internet usage, Social Neworking Sites and Our Lives, the independent research organization, Pew, reports that women are significantly more likely than men to "like" content on Facebook.



In addition, the youngest group of Facebook users surveyed, eighteen to twenty-two year olds, were found to be the most likely to "like" and to "like" content most frequently throughout a day - which portends increasing social interactions for brands in the future.

Brands take note! 
And you're welcome to join me on  Twitter or Facebook!

Confirmed: Most of Your Facebook "Friends" Are From High School

Confirming what we've long suspected, the highly-regarded, independent research organization, PEW, has just released a new report, Social Networking Sites and our Lives, that tells us that most of our Facebook "friends" are, indeed, the very folks we knew from high school....

Now, if you'll forgive me for returning to Twitter, where I'll be checking in on a few new ideas and folks from around the world...  @GlenGilmore

Ah, before I go, in case if you were still thinking that social networks are making us more socially isolated, think again:

2 Big Lessons from Morgan Stanley's Social Media Investment

Wall St. Bull photo - Wikipedia
1.  Tell Your Story in Social Media or Someone Else Will

Wall Street brokerage powerhouse, Morgan Stanley, made a bold investment decision:  within the year, all of its 17,800 financial advisors will be tweeting on Twitter and connecting on LinkedIn.  Bullish on Social Media, its head of U.S. sales, Andy Saperstein, proclaimed: 

MSSB is committed to continue leading our competition in innovation.  This will be a significant competitive advantage.

So where did Morgan Stanley break this bold announcement?  Well, ah, it didn't....That announcement came in an internal memo that was leaked to the press and whizzed through the corridors of social media until Morgan Stanley finally acknowledged that the memo was genuine.  Social media moves in real time.  Not having a presence in social media assures that you will be chasing the story rather than telling it.

2.  Just Because You're the Biggest, Doesn't Mean You'll Be the Best

Morgan Stanley, the world's largest brokerage firm, with over 60,000 employees, in 600 offices, in thirty-six countries around the world, has mind-boggling resources at its disposal.  What hope is there for medium-sized and small brokerage firms to compete in social media if such a giant is entering the arena?  There is great hope and opportunity for smaller financial firms to join the social media conversation and leap frog the giants.

Spam from 18,000 Brokers?

Glossed over by many reports touting Morgan Stanley's decision to invest in social media are the details of the announcement.  According to the internal annoucement memo, directed to an inaugural class of 600 of their most successful brokers who will be given the chance to begin using Twitter and LinkedIn by late June of this year, "You will have the ability, with a click of a button, to share pre-approved 'status updates' or 'tweets' with your social and professional networks."

Though the roll out will begin with 600 of its advisors in late June, it will include all of its nearly 18,000 financial advisor before year is out.  What will be the effect of 18,000 brokers tweeting the same "pre-approved" content?  Morgan Stanley could very quickly find its Twitter accounts suspended as Twitter has gotten much stricter about fighting spam and content farms.

Social media engagement that consists of scores of brokers sharing the same content from a library of pre-approved content is doomed to failure.  Smaller and medium sized firms that decide to follow Morgan Stanley's entrance into social networking, but with real commitment to human, real-time engagement, will quickly surpass Morgan Stanley in building a community and connecting with consumers.  Smart social media investors will manage their social media porfolio much more effectively if they follow not only the clear rules set by the financial industry's lead regulatory authority, FINRA, but the unwritten rules of effective social media participation:  it's about listening, learning, sharing and connecting -- not about spamming "pre-approved" content.

Smaller, independent brokerage houses that can move with greater agility and less bureaucracy, will have an even greater opportunity for social media success than larger firms that just don't understand the human component and real-time nature of social media.

The link to LinkedIn for the head of Morgan Stanley's U.S. sales, Andy Saperstein, who made the earth-shattering announcement about the firm beginning to use LinkedIn and Twitter, appears to be genuine as it is the only account bearing his name.  The effectively abandoned LinkedIn account,  with no connections, biography or photo, underscores the slow-moving nature of very large organizations even when they are making a seemingly bold, planned-out move.  It spells opportunity for the competition.

Your thoughts?  Will Morgan Stanley get it right?  Will smaller firms manage the investment better?  Will it be a good investment?

Please join me on Twitter!  @GlenGilmore

Related Reading:

Morgan Stanley to Tweet and Connect on LinkedIn

When Morgan Stanley Talks, People Listen

World's Largest Brokerage OKs Social Networking by Financial Advisors

Photo: Wikipedia

Memo heralds new media breakthrough

New York-based financial services powerhouse, Morgan Stanley, the world’s largest brokerage firm, announced, not in a tweet or a blog, but in an old-fashioned, internal memo, plans to “begin a staged, roll-out for Advisors to use Social Media.” 

Mincing no words about the implications of the announcement, the memo’s author, Andy Saperstein, who heads the brokerage’s U.S. operations, observed:


"This will be a significant competitive advantage."

Morgan Stanley’s decision to invest in social media by allowing, initially, a select group of about 600 of its financial advisors to use social media, will undoubtedly leave others in the highly-regulated financial services sector scrambling to follow the leader.

Regulatory Authority Guidelines Met with Industry Social Media Paralysis

Although the Financial Industry Regulatory Authority (FINRA) had provided the financial services industry with social media guidelines in January of 2010, the highly-regulated financial services sector largely greeted the Authority's invitation to participate in social media with paralysis.  Responding, nonetheless, to a keen, continued interest in social media by brokerages, FINRA even provided a session on social media compliance at its 2011 annual conference.

Technology Aids Compliance, Spurs Social Media Participation

A requirement of FINRA's guidelines is the archiving of social media communications, a particularly challenging compliance mandate.  To this requirement, Saperstein noted in his memo that:


In the coming weeks, Morgan Stanley will implement a technology solution that will capture and retain all communications on approved social networking sites to comply with regulatory requirements.

Although various archiving vendors exist, Saperstein's memo suggests a "technological solution" that may well be proprietary in nature.  Whatever it is, it will be closely scrutinized as an industry standard.

Limited Launch in Late June; Full Roll Out Within 6 Month
 

Announcing a tight timeline, Saperstein explained that the first 600 advisors would begin their social media participation in late June, "with access to LinkedIn and partial use of Twitter", with "the rest of the field" having access within six months.  (It is worth noting that Morgan Stanley reportedly reaped huge fees from recently underwriting LinkedIn's IPO.)


Firm to Provide Content for Sharing; Participation Preceded by Training and Profile Approval

Saperstein informed employees in his memo that the firm would provide "a tool for Advisors to distribute Firm approved research and content, providing you with a powerful way to share our unique intellectual content with clients and prospects."  Providing employees with content to share through social networks to clients and prospects could have a two-fold benefit:  it could ensure that the content shared was branded as well as scrutinized for regulatory compliance.


The lucky 600, who will become Morgan Stanley's social media pioneers, were also told that they would receive an e-mail "with more details on training and how to get started by getting your profiles approved."

No Mention of Facebook and Only "partial use of Twitter"

Interestingly, the memo makes no mention of the largest social network, Facebook, while stating that the financial advisors "will have access to LinkedIn and partial use of Twitter."

The glaring absence of any mention of Facebook may suggest that that particular social may not be part of the brokerage's initial social media roll out.  Like the risk-adverse pharmaceutical sector, another highly-regulated industry, wealth management may yet find too many unresolved compliance issues with Facebook.


Morgan Stanley An Early Student of "Significant Share Gains of Internet Traffic" by Social Networks

In 2008, Morgan Stanley noted the fast-growing role of social media in online communications, outlining "significant share gains of online traffic".

What are your thoughts?  Is social media a smart investment for the financial services?

Please make one small investment in social media - join me on Twitter!  GlenGilmore

For the text of the Morgan Stanley memo, see:  Tweet on the Street


5 steps docs can take to avoid 'social media missteps' - HIPPA

May 19, 2011 | Molly Merrill, Associate Editor
NEW JERSEY – While it is "critical that doctors, who have the best healthcare information to share, be part of the online healthcare conversation," says social media advisor Glen Gilmore, "there are definite precautions that should be taken to lessen the risk of social media missteps."  PLEASE FOLLOW LINK.

How To Use Facebook's Comment Moderation

Facebook's moderation tool helps page administrators keep the conversation clean

"Your first mission as our page administrator is to make sure that nothing on the page embarrasses us," clients often warn their community managers.  That task is a bit easier thanks to Facebook's moderation tool which allows administrators to create a list of words that are automatically blocked from appearing in the comments of the page.  This tool is particularly helpful to those in regulated industries, such as pharmaceuticals, who may even wish to not have certain products mentioned to avoid having to respond to a myriad of regulatory obligations.

How does the moderation tool (blocking words) work?

Facebook explains:

You can enter blacklisted terms from the settings section of the comments box. The content of new comments is checked against the blacklist of terms to see if this comment should have limited visibility. The comment is checked via substring matching. This means if you blacklist the word 'at', if the comment contains the sequence 'a' 't' anywhere it will be marked with limited visibility; e.g. if the comment contained the words 'bat', 'hat', 'attend', etc it would be caught.

So how do you create your list of blocked words?

1.  Once signed into your facebook page, click on the edit box you'll see on the right:


2.  Enter words in the "Moderation Blocklist" block, separated by commas, that you would like to have automatically marked as spam and not permitted to appear in the comments or posts on your page.



3.  To block the most commonly used profanities, select the level of blocking from the selections offered by the "Profanity Blocklist" tab.

4.  Don't forget to click, "Save Changes".

Your comments?  :)

Related Reading:

For more social media tips, please join me on Twitter at:  GlenGilmore and @SocialMediaLaw1


Feds: Employee Facebook Discussions of Working Conditions = Protected Speech



For employers who missed the National Labor Relations Board (“NLRB”) action last year against the Connecticut ambulance company that fired an employee for remarks she posted on Facebook about her supervisor, the NLRB has initiated another complaint against another employer, Hispanics United of Buffalo, a nonprofit, for similar grounds. 

In a press release about its latest complaint, the NLRB explained:

The complaint alleges that the Facebook discussion was protected concerted activity within the meaning of Section 7 of the National Labor Relations Act, because it involved a conversation among coworkers about their terms and conditions of employment, including their job performance and staffing levels.

Five employees were fired by the company after posting comments on Facebook about work load and staffing issues. The company, in its defense, contends that the five employees were fired because their online comments constituted harassment of another employee who had also posted a Facebook comment.

Unless the case is settled, the NLRB, an independent federal agency vested by Congress with the authority to safeguard employees’ rights to organize, will hold a hearing on the matter on June 22, 2011.  The case, however, is likely to settle and serve as another warning to employers that employees have a broad right to discuss conditions of their employment with coworkers on the social network of their choice:  as the NLRB has made amply clear, it is protected speech.

The complaint the NLRB had filed against the Connecticut company rested on similar grounds:  the company had fired an ambulance service worker after she had posted a series of negative comments about her supervisor on her personal Facebook page. Although the company contended that the firing was performance based, and there was also a dispute concerning the employee’s access to union representation during disciplinary proceedings, the NLRB focused on its determination that the employee was engaged in a protected activity when she posted the comments about her supervisor and responded to further comments from her coworkers.  The NLRB also cited the company’s social media policy as being unduly restrictive and violative of the right of employees to discuss workplace conditions.

The case was settled in February of this year and the NLRB used the occasion to give employers some clear guidance concerning the rights of employees to use social networks:

Under the NLRA, an employer cannot unduly restrict its employees’ ability to discuss terms and conditions of employment, regardless of whether a union exists, for fear that such restriction will impede employees’ ability to fairly unionize. At the same time, the NLRA does not provide carte blanche for employees to criticize or disparage their employers.

Simply stated, “employees may discuss the terms and conditions of their employment with coworkers,” on social networks.

In settling the case, the company “agreed to revise its overly-broad rules to ensure that they do not improperly restrict employees from discussing their wages, hours and working conditions with co-workers and others while not at work, and that they would not discipline or discharge employees for engaging in such discussions.”

Employers who have not revised their social media policies to make it clear that any restrictions stated within their guidelines in no way limit an employee’s right to discuss “the terms and conditions of employment” with coworkers are putting themselves at risk of action by the NLRB or setting themselves up for failure in the event that a dispute arises with an employee concerning their social network comments.  Even where other grounds for employee disciplinary action may exist, they are likely to be given little weight if a violation of an employee's right to "concerted activity" is found.


6 Things Pharma Can Do While Waiting For FDA Social Media Guidelines #socpharm



Although the FDA has its own Facebook page, Twitter account (actually, it maintains, at last count, nine Twitter accounts)a blog, a YouTube account, and Flickr account, it has once again disappointed the pharmaceutical industry by announcing another study that will further delay desperately-desired social media guidelines for the pharmaceutical industry.  While many pharmaceuticals have already waded deeply into to the waters of social media, just as many are concerned about the implications of not having clear FDA guidance. 

What can be done by pharmaceuticals as they await FDA social media guidelines?

  1.  Strengthen Your Social Media Team

Every pharmaceutical company needs to have an in-house social media marketing team, a group of individuals who are passionate about the digital and social space.  In addition to marketing leaders, the team should include representatives from human relations, customer relations, IT, and legal.  They should focus on further educating themselves in new media, its techniques, strategies, and tools, through ongoing training and conference participation.  They should be setting goals, establishing policies, and eventually providing the in-house training that will help the larger organization understand the integration of digital and social marketing.

2.    Know the Social Media Guidelines that Do Exist
Alhough pharma always thinks of the FDA when it considers social media guidelines, companies are also well advised to understand that the U.S. Federal Trade Commission (“FTC”) is charged by Congress with stopping “unfair and deceptive acts or practices.”  The FTC wasted little time in updating, in 2009, its revised Guidelines Concerning the Use of Endorsements and Testimonials in Advertising, found in 16 C.F.R. Part 255, to address marketing within social networks.  Since revising its Guidelines, the Commission has been vigilant in pursuing perceived violations of the updated rules.  Nonetheless, many marketers remain oblivious to the guidelines, risking sanctions that can cause serious damage to their brands.
In announcing the guidelines, the FTC offered a detailed summary of the provisions relating to social media: 

The revised Guides also add new examples to illustrate the long standing principle that “material connections” (sometimes payments or free products) between advertisers and endorsers – connections that consumers would not expect – must be disclosed. These examples address what constitutes an endorsement when the message is conveyed by bloggers or other “word-of-mouth” marketers. The revised Guides specify that while decisions will be reached on a case-by-case basis, the post of a blogger who receives cash or in-kind payment to review a product is considered an endorsement. Thus, bloggers who make an endorsement must disclose the material connections they share with the seller of the product or service. Likewise, if a company refers in an advertisement to the findings of a research organization that conducted research sponsored by the company, the advertisement must disclose the connection between the advertiser and the research organization. And a paid endorsement – like any other advertisement – is deceptive if it makes false or misleading claims.

     3.    Review and Update Your
            Social Media Guidelines

Many companies, in the rush to restrict employee social media participation, adopted social media policies that prohibit virtually any discussion of workplace matters online.  Such policies may run afoul of the National Relations Labor Board (NLRB), which has initiated actions against companies where their social media policies were deemed to be too restrictive of employee conversations relevant to workplace conditions.  The NLRB objection to such restrictive social media policies transcends the issue of whether a workplace is unionized or not:  the dispositive question is whether the social media policy prohibits workers from discussing their "terms and conditions of employment."

With over 640 million Facebook accounts, 300 million Twitter accounts, 100 million LinkedIn accounts, and over 7.4 million people on Foursquare, your employees need clear guidelines.  Social media policies should be crafted to give real guidance to employees, without interfering with an employee's protected right of discussing working conditions.  
    4.  Develop A Social Media Decision Tree

Where companies are engaging in social media, employees need clear guidance and a streamlined process on how to engage in social media.  The U.S. Air Force wrestled with this issue and created a decision tree, which Pfizer Canada modified for its employees.  It’s a model every company should strive to perfect.  

     5.  Make Sure Every Employee Understands
         “Adverse Events” Responsibilities

Pharma’s biggest fear.  With employees listening on social media everyday, throughout the day, policies must be updated to ensure that all employees have a clear understanding of what they are to do should they become aware of such an event.

  1. Listen, Respond, Share and Community Build
A.  Use Social Media to Educate and Share Wellness Tips


B.  Use Social Media to Let Brand Advocates Share Their Stories


C.  Use Social Media to Share the Social Good You're Doing



For more suggestions, please join me on Twitter at @HealthcareSMM  Your thoughts?

4 Tips for Social Media Community Managers


1.  Have fun.

You won't succeed in social media unless you learn to have fun with it.  Social media community building and management is a lot of work.  You need to consistently find great content to share.  You need to pay attention to your community and engage your community.  You need to grow your community.  It is labor intensive.  You will only succeed in doing these things well if you figure out to how to have fun while doing them.  Only you can figure out how to do that, but do it.

2.  Share what inspires you.

This relates to the first point.  Follow and share what inspires you, what excites you.  If you do, you will almost certainly inspire and excite others.  The greatest teachers are always those who love their subjects.  Even when you are creating content for others, find that element of the subject that excites you; it will likely be the best method of finding the best content. 

3.  Look for others to join in the fun.

Social media is all about community building.  Consider those who would likely enjoy the content you are sharing.  Find them by the content they share.   Retweet their content.  Comment on their content. 

And keep in mind, as you work to build your community, that while content may be king, relevancy builds a kingdom.

4.  When things get really hot, look for a hydrant to open up.

What?  Not everyone has a pool.  Figure out what folks are thirsting for and find a way to bring it to them.
Please let me know your thoughts!

And please join me on Twitter:  @GlenGilmore

What You Should Know About the EU's "Internet of Things" Privacy Framework

A practicing attorney and social media strategist, Glen Gilmore teaches Digital Marketing and Social Media Law at the Rutgers University Center for Management Development

EU "Privacy" Framework Heralds
the "Internet of Things"

To many, "The Internet of Things,"  a predicted, transformative moment in time when nearly all “things” in the physical world will be interconnected, wirelessly, with communication capabilities linking the physical and virtual worlds for a variety of cooperative applications, is a distant point in the future.  To others, the internet of things is now.




RFID "Smart Tags" Connecting
Physical Things to Virtual Things

Radio-frequency identification technology (RFID), a technology that uses "smart tags", tags with microchips, to provide information to a virtual network, is considered to be a primary technology in advancing "the internet of things."  In 2011, RFID revenue was expected to exceed $6 billion,  with more than 750 million so-called "item-level" RFID tags  used in global apparel markets alone.  In Europe, about one billion "smart tags" are being used, linking many "things" to the virtual world.



The European Union (EU), representing twenty-seven member states, has expressed grave concerns about the privacy implications of an unregulated internet and unchecked technology.



Responding to the privacy concerns it perceived as being presented by the "the Internet of Things", the EU, in 2009, adopted a fourteen-point strategic plan of action:

EU's 2009 Internet of Things:
14-point Strategic Action Plan

1.  Governance. The Commission will work on the definition of a set of principles underlying the governance of the Internet of Things and the design of an architecture endowed with a sufficient level of decentralised management.

2.  Privacy and data protection. The Commission will observe carefully the application of data protection legislation to the Internet of Things.

3.  The right to the "silence of the chips". The Commission will launch a debate about whether individuals should be able to disconnect from their networked environment at any moment. Citizens should be able to read basic RFID (Radio Frequency Identification Devices) tags – and destroy them too – to preserve their privacy. Such rights are likely to become more important as RFID and other wireless technologies become small enough to be invisible.


4.  Emerging risks. The Commission will take effective action to enable the Internet of Things to meet challenges related to trust, acceptance and security.

5.  Vital resource. In connection with its activities on the protection of critical information infrastructures, the Commission will closely follow the development of the Internet of Things into a vital resource for Europe.

6.  Standardisation. The Commission will, if necessary, launch additional standardisation mandates related to the Internet of Things.

7.  Research. The Commission will continue to finance collaborative research projects in the area of the Internet of Things through the 7 th Framework Programme.

8.  Public Private Partnership. The Commission will integrate, as adequate, the Internet of Things in the four research and development public-private partnerships that are being prepared.

9.  Innovation. The Commission will launch pilot projects to promote the readiness of EU organisations to effectively deploy marketable, interoperable, secure and privacy-aware Internet of Things applications.

10.  Institutional awareness. The Commission will regularly inform the European Parliament and the Council about Internet of Things developments.

11.  International dialogue. The Commission will intensify the dialogue on the Internet of Things with its international partners to share information and good practices and agree on relevant joint actions.

12.  Environment. The Commission will assess the difficulties of recycling RFID tags as well as the benefits that the presence of these tags can have on the recycling of objects.

13.  Statistics. Eurostat will start publishing statistics on the use of RFID technologies in December 2009

14.  Evolution. The Commission will gather a representative set of European stakeholders to monitor the evolution of the Internet of Things.

The "Internet of Things" Privacy Framework

Completing the promise of their earlier action plan, the EU and private stakeholders, with a simple, two-page press release and signing ceremony in Brussels, on April 6, 2011, announced that they had established of a voluntary Privacy and Data Protection Impact Assessment Framework for RFID Applications", dubbed the  "Internet of Things Privacy Framework" by the New York Times.  Specifically, the framework establishes “guidelines for all companies in Europe to address the data protection implications of smart tags (Radio Frequency Identification Devices – RFID) prior to placing them on the market.”

At the signing ceremony, one industry representative observed, “Data protection authorities sometimes seem to be one-track minded and force compliance with data protection rules….Today, we have overcome this very unfruitful deadlock….” Despite the fanfare of many signatures, the framework is voluntary, with no express auditing mechanisms, though record-keeping procedures are outlined, and no defined penalties for non-compliance.

Coincidentally, the announcement of the EU’s voluntary framework came within one week of the release of a report by Carnegie Mellon University showing “lagging compliance” with U.S. industry self-regulation in online behavioral advertising.

Four-step Privacy Impact Assessment (PIA)  

Under the Commission’s framework, RFID operators would be required to complete a four-step Privacy Impact Assessment (PIA) process prior to introducing a new RFID application into the market:
1. Describe the RFID Application;


2. Identify and list how the RFID Application under review could threaten privacy and estimate the magnitude and likelihood of those risks;

3. Document current and proposed technical and organisational controls to mitigate identified risks; and

4. Document the resolution (results of the analysis) regarding the Application.


Let the Internet of Things Begin!



So what is the most significant impact of the framework? Privacy? Perhaps not. Instead, the real significance of the framework may have been captured in an observation made in the official press release from the signing, namely, that the framework will give the business sector the “legal certainty that the use of their tags is compatible with European privacy legislation.” In other words, the framework gives private stakeholders the green light to continue full-steam ahead with their already massive investment in RFID technologies and the “internet of things” it heralds.

Why might industry leaders have been concerned about limitations on RFID technologies?  The EU has also just reaffirmed its commitment to "Privacy by Default" as the core of its data protection laws.  So Europeans are now given "the right to be forgotten" online and the right to be remembered in real life...
The Internet of Things?

The EU Commission website provides an example to illuminate the “internet of things”:

Take one example: a suitcase itself can indicate which plane it should be sent to. This is possible thanks to Radio Frequency Identification (RFID). With RFID, more and more objects communicate with each other, slowly creating a network of information, a so-called ‘internet of things”.

This network could potentially make our lives much easier…No need to worry about your suitcase being sent to the wrong plane anymore! But we must also be careful how we use it, and avoid certain pitfalls.

Thanks! Your pants just told us where you are.

Worried that your smart phone is broadcasting your whereabouts?
Your pants may be doing the same.

What sort of privacy concerns are raised by RFID tags?

According to the commission, one concern the new Framework seeks to address is “the possibility of a third party accessing your personal data (e.g., concerning your location) without your permission.” How could that happen? Well, the pants you just bought might come with a small, RFID tag that has an “electronic memory that is readable and perhaps writable, and antennae.”

The U.S. Approach


The U.S., in a staff report from the Federal Trade Commission (FTC) concluded:

The FTC staff also agrees with the EC that there is a need to raise consumer awareness about RFID technology, in order to enhance consumer trust and to give consumers the tools to protect themselves from the risk of misuse of their information. Given the current stage of deployment of consumer-facing RFID applications, however, the FTC believes that mandating or encouraging specific technological tools for protecting consumer privacy is premature.

How Will the Internet of Things Be Social?

The New York Marathon provides a great example of how the "internet of things" will interact with the virtual world and integrate with social:




What are your thoughts?  Please let me know!

And please join me on Twitter:  @GlenGilmore and @SocialMediaLaw1