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Creating a Social Media Policy for your Casino

There are a few casino properties that have not taken the time to create a social media policy.  Some, not all, casino properties that have created a social media policy have written a social media policy that is poor.  A poorly written social media policy can restrict and kill social media engagement, which is the exact opposite of what social media is suppose to do for the business.

Social media policies should support and empower high-quality engagement.  It is about empowerment and trust.  Some casinos have adopted the idea that an advertising agency can be responsible for social media for the property.  It will only be successful if there is constant contact between the casino and the advertising agency.  Also the discussion between the casino and the advertising agency needs to be clear.  Realize that the advertising agency is now a third voice for communication to take place between the casino and the public.  Just like in grade school; if you get to many people in the middle passing along the story, the story will change before it reaches it’s audience.  Some casino properties try to stay away from social media because they do not trust an employee to be online and / or they do not trust their advertising agency.  The policy of putting the social media responsibility into the advertising agency can also kill social media engagement.  The reason it kills the social media engagement is because an advertising agency begins to use social media as an advertising channel and not as a real-time marketing tool and building a relationship with customers and engaging in a conversation with customers.  (example: Here are the winners of our poker tournament!  – This announcement has no way to engage in a conversation with your customers) (This will be covered in a later discussion)

Why have Social Media Policies?

Social media policies are different. In most policies and procedures, we document what staff should do in certain situations: “If this happens, do that.” For social media, there is no way to know exactly what situations may arise – or in many cases – how staff should best handle them. Each social media network and each relationship is unique and the social media environment changes daily.  “No way to know exactly what situation may arise” – A great example was the way MGM handled the big crowds of people that were in Mandalay Bay the night three major events were taking place at the property.  The staff at MGM got onto the social media channels and informed the public that they were aware of the crowds and were working on the efforts to get people in and out safely and in a timely manner.  A majority of the comments directed back to the Mandalay Bay by the public through the social media channels were comments of gratitude, thanking Mandalay Bay for being aware of the situation and trying to do something about it.  A great example of real-time marketing.  Within minutes of the situation taking place, the casino was able to inform the public that they were aware of the situation and were working on it, and also within minutes of making the public aware, the customers were able to provide feedback.

The courts are in the process of interpreting laws in regards to social media. Until that interpretation process is mature – and this will take years – organizations will be operating without definitive guidance. Issues that may arise include: employee and/or client confidentiality, labor relations issues, brand jacking, miscommunication, spamming, etc.

Given an uncertain environment, how do casinos move forward using social media?

Listed below are areas that your organization can use to begin your social media policy for your casino.

Gather Your Team

A social media policy cannot be written by one person alone. It must be unique to your property and ideally should include input from many different people from different departments.

A team approach ensures that key areas of risk are managed properly and that any future challenges that may arise are handled appropriately.

Besides the staff directly involved in social media, potential team members might include: CEO, General Manager, HR Director, IT Director, Marketing Director, Hotel Director, may be all department heads, Legal Council and at least one person that has a complete understanding of social media, even if it is an outside source.

Not every member of this team needs to be aware of the intimate details of your social media activities. Think of it this way: if a crisis should occur, what information does your team need to have (about the social media and legal landscapes as well as your organization and values) in order to respond appropriately on social media?

Who needs to be on your social media team?  How does it compare to who is on your crisis management team?  Or does your property have a crisis management team in place?  Does the other employees from all of your departments know who is the social media team or crisis management team?  The other employees from the other departments should be informed of these teams.  If a situation should arise, employees would know who to turn too on either one of these teams.

Focus on Creating Culture

Social media changes every day. Bureaucratic policies aren’t likely to be successful. Instead, create a culture of innovation, idea-sharing, problem-solving and creativity. There is a direct link between internal organizational culture and policies. In fact, the policies that are put in place shape the culture of the property.

As you write your policies, include processes that reinforce a culture of evaluation and learning. Here are some questions to consider:

  • Who is on your social media team?  Does the social media team reflect the crisis management team?
  • How often does the social media team meet?  What is covered in the meetings?  Is there a 3 month, 6 month, 12 month plan in place?
  • How are problems/challenges handled and by whom?
  • How will successes be evaluated and what will be learned from failures?

In your policies, you can acknowledge the social media cultural values of transparency, consistency, connection, creativity and promptness. With these values in mind, build processes that emphasize training, support and evaluation.

If the concept of social media culture is new to your casino property, and / or your property does not believe in social media,

Consider Legal Ramifications, Including the National Labor Relations Review Board (NLRB)

Many of the court cases coming out about social media are labor relations issues. The National Labor Relations Act (NLRA) was enacted primarily to protect employees’ rights to organize.

Traditionally, employee organizing took place in person or over the phone. With the advent of social media, it also takes place online. It doesn’t matter if employees are unionized or not; they have the right to discuss conditions of employment with fellow employees.

This means that even a casual conversation on Facebook about working conditions may be protected under the NLRA. Each situation is different, but the bottom line is this: be very careful about telling employees what they can and cannot do on their own personal social media sites. This language can quickly backfire.

In August 2011, the NLRB issued a memo regarding 14 of these cases. This memo provided explanations of the cases as well as the reasoning behind the decisions made. I highly recommend that employers read this memo and share it with everyone on the social media team.  The link to this article is below:

http://mynlrb.nlrb.gov/link/document.aspx/09031d458056e743

Memo dated 8/18/11 from the National Labor Relations Review Board.

Separate Overall Policies from Site-Specific Guidelines

The social media landscape changes every day. If your policies are narrowly focused on a specific social media site, they will be out of date pretty quickly. There are thousands of social media sites.  In general, the policy should focus on the big picture: who does what (roles and responsibilities), a general overview of how they can/can’t do it (legal compliance and branding, for example) and why we do it at all (purpose and values).  This applies strongly to the casino properties that believe that facebook, twitter and linkedin are the only sites for social media.  At the last presentation I gave at G2E 201, there was a discussion on what sites were considered social media.  Many properties are adopting the definitation that social media is any site that the public can openly express an opinion of your property, this includes sites such as yelp, foursquare, tripadvisor, etc.

Separate written guidelines can be created to record the nitty-gritty specifics of a certain social media site. These guidelines help tremendously in the case of staff turnover. The process of drafting guidelines also helps staff to better understand and explain what their expectations are how they engage on social media sites.

Don’t Reinvent the Wheel

It’s likely that you already have many internal policies in place that apply to social media activities. This includes policies about privacy, photo consents, Internet usage, cell phone usage and many others.

You can reference these policies in your social media policies, taking special note of any differences in application that may be necessary with social media.

For example, your cell phone usage policy may not currently discuss the use of photos from cell phone cameras. Thanks to geotagging, photos taken by cell phones almost universally contain digital coding which betrays your exact location on the date and time of the photo. If you upload a photo taken by a cell phone camera to your social media sites, you might be giving away more information than necessary.  Depending on the jurisdiction of your casino, you may want to include in your social media policy, the policies of the gaming commission regarding photos being taken on the casino floor.

A social media policy might take this into consideration by requiring staff to use software to strip the photos of geotagging information before the photos may be posted.  include in your policy the consent of winners being announced on your social media sites.

Include External Regulations

Most legal regulations (including HIPAA, FERPA, fair employment, etc.) are in effect online as well as offline. Use the social media policies to remind employees that these regulations must be adhered to. Where possible, give explicit examples of what types of behavior are not acceptable.

P.S.: This is a good time to think through your corporate compliance training. Social media is affecting just about every aspect of our lives and businesses. If your training on privacy, confidentiality, branding, etc., don’t currently discuss social media, it’s time to include it.

Create Two Policies

It is considered a best practice to have two social media policies: one for employees using social media for their job and one for employees using social media in their personal lives.

The first policy, focusing on job-related activities, should cover everything that has been discussed here: defining your team, articulating roles and responsibilities, branding guidelines, and becoming clear about what internal and external policies must be complied with.

The second policy, focusing on employees using social media in their personal lives, should give employees information about what they can and cannot say about your company on their personal site.

Each casino will want to be very specific about what employees are not allowed to share online.

For example, trade secrets, client information and even employee whereabouts might be kept strictly confidential. Other organizations will want to encourage employees to act as brand ambassadors. Some even go so far as to provide guidance as to how to talk about the company online. However you’d like your employees to discuss (or not discuss) your company online, give them guidance.

Two words of caution: 1) It is dangerous and not recommended to require employees to use their own personal social media accounts to connect with your casino online. They may choose to do so, but let that be their choice. The last thing any manager wants is to learn more about an employee’s private life than he/she needs to know. 2) Before you write the policy, reread the Legal Ramifications paragraph above and the memo from the National Labor Relations Review Board. It may save you a lot of headache down the road.

Emphasize Education

The boundaries sometimes between our personal and professional lives are blurring. Most employees haven’t fully realized the challenges that may develop as a result of decreased privacy. The old saying was, “What happens in Vegas, stays in Vegas.” Today, a more accurate statement is, “What happens in Vegas, stays on Facebook and Youtube.”

It seems that many of the court cases on social media arise out of ignorance, not malice, on the part of the employee. Many employees haven’t fully thought through the consequences of their cyber-behavior. By providing cyber-safety education to their staff, employers are preventing problems before they start.

Just as your casino property has two policies, one for job-related activities and one for employees using social media in their personal life, employee education can also take two tracks:

  • Provide job-related training to staff engaged in social media on the organization’s behalf. Ongoing, regular training helps keep your organization current and gives staff an opportunity to network with others in the field.
  • Educate all staff on Internet safety. This education might include how to protect ourselves from cyber-crime and how to establish and protect our online reputation.

When it comes to responsible cyber-behavior, employers have a unique opportunity to educate rather than mandate. This commitment demonstrates respect for the employees. Employees feel valued, trusted and inspired. Everyone benefits.

Ask a Lawyer to Review the Policy

Legal advice is critical. It is easy to misstep, especially in the areas of labor relations. Make sure you ask an attorney who has experience in the area – your HR Director may not have all the answers to a policy.

Legal review can be expensive; however, a lawsuit would be exponentially more costly.

Don’t Let it Collect Dust

The cyber-environment changes frequently. Social media policies should be reviewed at least every six months. Let everyone on the team review the policy separately and then together.

Ask yourselves, is this still relevant? Does this help us do our jobs? How has the social media environment changed recently? Are there any legal updates that apply?

Policies are not the most exciting part of social media; however, if the policies are developed well, they can support, empower and engage the staff as they in turn engage your clients.

Social Media Examinar 2/9/2012

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