The FCA and Social Media - Insurance Brokers are you ready?

If you work in UK general insurance, you would have had to be living in Siberian with no contact with the outside world not to pick up on the fact that the Financial Conduct Authority mean business.  A quick look at headlines since its formation shows ‘they ain’t messing’.  Rhetoric from Martin Wheatley like ‘Shoot first, ask questions later’ shows that he subscribes to Acta Non Verba. 
And exactly how many ‘Thematic Reviews’ is that so far?
How long before insurance brokers use of Social Media becomes the the subject of FCA scrutiny?
Whether or not it does or doesn't, insurance brokers should be alive to making sure that they are prepared and have procedures in place to ensure that their activity is being managed professionally.
For most insurance brokers marketing is a core function and as part of their efforts some are increasingly turning to social media as another means of communicating with clients and prospects.
On the whole it looks like things are trucking along quite nicely with new Twitter accounts springing up almost daily.  Like all things, some seem to be getting it more right than others. That said; there are a small minority of companies that appear to be using social media without fully appreciating that the normal rules for communicating with clients and prospects apply.
For the purposes of this blog, I am defining anything that appears online, as well as the likes of LinkedIn, Twitter and Facebook etc as social media.  I say this because this includes comments you or your employees might decide to leave on a website.  If you or your colleagues were able to make any comments online, the chances are that they will be there for the world to see, including your clients and potential clients.
To test this I would urge every reader of this blog to Google themselves.  You might be surprised what comes up.  The punch line is, if you can see a comment so can everyone else and if that wasn’t bad enough it might be visible online forever.  
Here are some useful things to consider:  
Be careful what you share in Social Media 
Social media is a great medium but use it sensibly. Avoid making product recommendations of any kind on social media channels. The fact is, at best it’s a broadcast tool, which let’s face it most social media channels are and you don’t possess anything like enough information to make a recommendation that would satisfy regulatory expectations (demands and needs etc).
Have a company Social Media Policy
Have set clearly defined rules in place about what can and can’t be posted. Some companies include these as part of their terms and conditions of employment. This is part of good governance, something I guess you would have to satisfy the FCA on should they come knocking on your door.  
Having a social media policy can also help shape and build corporate brand – nothing worse than seeing a whole bunch (not sure if that is the correct collective known) going off in all directions and tones of voice when they work for the same company – talk about customer confusion!

Also consider employees that may have some notary within your marketplace. What happens if they have a private account and don’t mention your company at all on their profile, but given their standing and profile will still be associated with your business?  What if they post something privately but it’s completely inappropriate – is there a linkage back to your brand and the type of people you employ? 

Don’t be negative even if you really really want to be 

Avoid online negativity online at all costs.  Posts of this kind can hang there for years and come back to bite you on the bum. Least of all, it probably just isn’t terribly professional, so don’t do it. Remember you are leaving a trial back to your door.

Brace yourself Shelia
The World is strange, full of strange and interesting people.  Now a small and thankfully tiny minority of these very strange and interesting people will, whilst you are being totally well behaved on Social Media, come along and broadside you with NEGITIVITY.  
This shouldn’t come as a shock.  Be prepared.  To be on the safe side you should have a policy in place that tells everyone in your firm what to do so that you can satisfactorily manage any negative comments made and secure a favourable outcome.  Remember people are using sites like Twitter to shout at companies publically.

Record your activity 

If there is one thing that regulators seem to love its record keeping. Consider using social media archiving software to keep records of what you and your colleagues said and what was said about you.  Should the FCA come knocking, it will certainly be a good thing that you have your own evidence. As a minimum it will show them that you take this subject seriously 


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