“TD Bank has a subtle approach as a consumer-facing bank. In July we turned ATM’s into “thanking machines” to reward customers. We also offer coin changers, lollipops and dog treats”, said Albert Raymond, TD’s head of U.S. privacy and social media compliance. But as part of the regulated financial industry, TD Bank takes serious measures with social media.
Raymond discussed TD’s social media programs and the tradeoffs involved at a recent BDI Summit on the future of financial communications in New York. “Compliance and social media are now higher profile topics, but financial companies take an inherently conservative approach to the use of technology and social media since there’s a strong trust factor involved”, he said.
“FINRA (Financial Industry Regulatory Authority) offers guidance on social media, though there haven’t been major changes from the offline world”, Raymond said. “We still must monitor and retain customer communications. Financial orgs have a playbook with 7 areas serving as a social media reference point so financial companies don’t need to create programs from scratch.”
Other selected comments from Raymond provide clues regarding how TD Bank handles social:
Social media policy:
“TD Bank developed a social media policy as the bedrock of our program. We combined our electronic and social media policies to roll out to our employees in the U.S. and Canada. It offers guidance, and we look for precedents and a reasonable approach. Privacy involves risks and we need to determine brand and reputation risks.”
Platforms and tracking tools:
“We use platforms and suites of tools like Actiance to capture internal and external communications. Messages between employees and customers and among employees must be monitored and archived.”
“We don’t prohibit or block the use of social media at work since employees will find a way around it. So we put rules or frameworks in place regarding what they can and can’t do on social media. If users represent themselves as employees of TD Bank on social media, we need to ensure they don’t share information like salaries, since that’s not allowed.”
“We have authorized users for each TD social media platform, like Twitter, Facebook, Pinterest, etc. Globally we monitor conversations regarding TD Bank, including customer mentions of the brand and experiences with the bank. When we get complaints, it depends on the severity and how influential a social media user is. We quickly respond, provide a specific telephone number, not the call center, to take social conversations offline.”
Challenges – containment and balance:
“Getting everyone on board is difficult. In the past, we had more ability to control employees and build a moat, but not with social media. If they shared the wrong information on paper, it wasn’t as bad, but it’s harder to contain breaches in a digital context. Downstream they may impact a bank’s reputation, especially data breaches. And as we know, sometimes off-the-cuff comments become media events. Still, we don’t want to be contrived or boring on social media, so we need to balance both sides.”