Jordan SchwartzSocial Collaborations Associate
http://www.linkedin.com/in/jordanLschwartz https://twitter.com/schwartz_jordanhttp://www.facebook.com/jordanactiance
Enabling Social Media
About Actiance, Inc
A decade of expertise, a history of firsts
Global Operations
• 3 US offices, three continents• 210 employees
Dedicated Social Engagement Team
• Partnering: networks, platforms, service providers
• Regulators: FINRA, IIROC, FSA, SEBI…
• Best Practice enablement, education
Client Engagement
• 9 out of the top 10 US Banks, Top 5 CDN Banks
• 284 FINRA firms
• 84,000 Social Networking users under license
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ONE Platform to Manage & Secure ALL your Communications & Collaboration
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Why Customers Select Actiance
“We chose Actiance because they had the resources and partnering culture to help us with our long term strategy”
– VP Technology, Interactive Marketing, Top 3 Wirehouse
“Actiance’s platform allows us to execute our long term vision of integrating our internal social platforms with consumer networks”
– SVP & CIO, Major Mutual Fund Company
“Socialite Enable and Engage offer the best mix of compliance and marketing capabilities allowing our advisors to develop their personal brands”
– Marketing Director, Top Regional Brokerage
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97.09% of people questioned in a survey said their
buying decisions are influenced by social groups.
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
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A majority of respondents indicate using social media for one or more business purposes.
SOCIAL MEDIA USAGE
For which of the following business purposes do you use social media today?
Base: all respondents in 2012 (1,428) and 2011 (1,597); multiple responses.
Social media usage
Respondents under 35 are more likely to use social media for business purposes than those 55 or older (68% vs. 45%)
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Social Media Maturity Curve
Pre-Consideration
• No Social Presence
• Restrictive social policy
• No Social Tools
• Need to: identify options, best practices
Early Consideration
• Some Corporate Presence
• Banned/ restrictive policy in place
• Pilot program for content distribution might be in place
• Need to: justify distributed teams usage
Early Adopters
• Corporate Presence
• Acceptable use policy
• Social media being used by distributed
teams/advisors
• Need to: use social to develop, strengthen relationships, for some also as a sales channel
Early Majority
• Corporate SM presence
• Social media usage by distributed teams advisors
• Acceptable use policy
• Next step, use social to develop, strengthen relationships, for some also as a sales channel
• Previous concerns about FINRA and/ or impact of social media overcome by market acceptance and demonstrable results.
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Six Social Principles for Success
Crowdsource ContentDevelop Personal BrandCreate Integral Strategy
Measure & AnalyzeEducate and TrainLeverage Customers
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Partnering for Results: The Actiance Approach
Our goal is to enable your extended team to leverage the right social media channels to safely, effectively and compliantly strengthen relationships, to build their business and socially interact with clients
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Monitoring, pre and post review, archiving and surveillance
Enterprise Solution Hierarchy
10
Content and usability are critical to success…which becomes immediately apparent once compliance is in place.
ENTERPRISE NEEDS FOR SOCIAL ENABLEMENT
CRM, workflow, content and marketing materials
To build a loyal, tuned in following requires above all else—relevance and authenticity
MUST be quick, intuitive, easy to use for FAs. Not another chore
Enterprise Solution Hierarchy
11
Content and usability are critical to success…which becomes immediately apparent once compliance is in place.
Socialite Enablefeature and content security and compliance for Facebook, LinkedIn and Twitter
Socialite Engageprotect brand and ensure compliance while allowing employees to share relevant content, measure impact and increase engagement
Socialite Enable Secure & Compliant use of Social Networks
Identity management
ActivityControl
Granular Application Control
Anti-Malware
Data Leak Prevention
Moderation Logging and Archiving
Export of Data
Socialite Engage Communicate, Measure, Nurture
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Content Sources Internal Thomson Reuters Dow Jones Equilar
Enterprise Integration Receive Event Triggers Send Opportunities
Focus on the Important Key Connections Search Alerts
Measurement and Analytics ID Key Influencers Evaluate Platforms Time of Day Length of Conversation Type of Engagement
Actiance customers build new business and stay connected with clients
UK’s Largest Corporate Bank now enables clients to engage with each other and the Bank in an online community.
An FA at a major wire house client noticed a new LinkedIn client changed her status to “retired”, in mailed her, and ultimately won a $2.75m new account
An FA at a regional wire house client landed a $1m new account after only 93 tweets of moderated content were sent through Socialite
An FA at a national wire house client with deep energy industry experience and new to the wealth management world, used LinkedIn securely through Socialite and in a few weeks constructed a network of 400+, global energy industry contacts he could then effectively prospect to
At a national wire house client, 1000 FAs signed on to use social media through Socialite in the first three weeks of its enablement
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How can we help further? OR
Let’s take a look
Thank you
Name in boldPosition in CompanyLINKEDIN PROFILEFACEBOOK PAGETWITTER ID
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Pocket Slides: The Actiance Platform
Actiance Vision
ONE Platform to Manage & Secure ALL your Communications & Collaboration
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The Actiance Platform
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Web
2.0
Conn
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Web
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Available Today RoadmapQ1 2012
Channel Interface
APIInsert
Search
ExportActive Content Store
Unified Identity and Policy Management
Actiance ApplicationsClassification, Retention, Tagging, eDiscovery, Legal-Hold, Business Analytics
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Socialite Engage – Unified Engagement Platform
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Face
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Conn
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Unified Identity and Policy Management
Teaming and WorkflowRa
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Coming Soon
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Analytics – Measurement, Reach, Velocity
Unified View – Content Aggregation and Syndication
Roadmap
APIInsert
Search
Export
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Pocket Slides: Risks
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
The Challenges of Social and Financial Services
Doing Nothing Doing Something Badly
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Gartner Research - Andrew Walls
“Do You Need a Social Media Security Policy ?”
“Social media is not a separate silo unto itself. It’s simply another form of
electronic communications – customers should look at expanding their
existing electronic communications policies to incorporate social media.
Customers should consider replicating policies from other communications
modalities across social media.”
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FINRA Guidelines: Regulatory Notices 10-06 and 11-39
SEC Rules 17a-3 and 17a-4 and NASD Rule 3110 Retain records of communications related to business
Public Appearances Electronic forum & chat rooms, content posted to social media may constitute a public appearance
Prior Approvals Wall postings may require prior approvals
Participation Real-time participation on social networks equals participation
FINRA Regulatory Notice 07-59 For instance, communications between research and investment banking departments should be restricted
Restrict PersonnelOnly those subject to firms supervision should have access, provide training prior to engagement, prohibit or restrict those who pose a compliance risk. Restrict access with technology.
Regulation Social Network and Web 2.0 Impact
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The First FINRA Sanction for Social Media
Jenny Ta
FINRA found that Ta failed to inform a registered firm principal that she had a Twitter account which, on occasion, she used to tout a particular stock. FINRA determined that Ta’s “tweets” were unbalanced, overwhelmingly positive and frequently predicted an imminent price rise, and Ta did not disclose that she and her family members held a substantial position in the stock. Fined $10,000. Suspended one year.
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MR0281 Provides guidance on the review, supervision, and retention of sales literature, advertisements, and correspondence
Rule 29.1 Anonymous representations or recommendations are improper.
Rule 29.7 (1) Advertising and sales literature shall not be false or misleading.
Rule 29.7 (2) Written policies and procedures shall be in place regarding the review and supervision of sales literature related to the business.
Rule 29.7 (3) Some types of sales literature must be pre-approved by a supervisor.
Rule 29.7 (5) Recordkeeping requirements - two years for advertisements and five years for all correspondence
National Instrument 31-103 Firms must retain records of all their business activities and communications.
Regulation Social Media and Web 2.0 Impact
IIROC Guidelines
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FSA Guidelines
Senior Management Arrangements, Systems and Controls (SYSC)
SYSC 9.1.1
An enterprise must arrange for orderly records to be kept of its business and internal organization.
SYSC 9.1.2 Records must be kept for at least five years.
SYSC 9.1.5 An enterprise should have appropriate systems and controls in place with respect to the adequacy of, access to, and the security of its records.
Policy Statement 08/1 Must record conversations on public and enterprise IM networks.
SYSC 3.1 A firm must take reasonable care to establish and maintain such systems and controls as are appropriate to its business.
SYSC 10.2 Firms must take reasonable steps to ensure that ethical walls remain effective and are adequately monitored.
Financial Promotions Industry Update No. 5
All communications or financial promotions must be based on the principles of fair dealing. Adequate records of financial promotions must be kept.
Regulation Social Network and Web 2.0 Impact
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SEC Alerts: January 2012
*Dually registered firms must adhere to both SEC and FINRA rules.
Types of Financial Advisors
Registered Representatives (Broker-Dealer)*
Investment Advisors (Registered Investment Advisor)*
Regulated by FINRA and the SEC Regulated by SEC or state regulators
Paid via commission Paid fee by client
Suitability- recommendations must be consistent with best interest of clients
Fiduciary responsibility – must place clients interests above own
Ethics Legality
Transactions Advice
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Securities Exchange Commission, January 4
Charges Illinois-Based Adviser in Social Media Scam
Investor Alerts: Social Media and Investing
– Avoiding Fraud
– Understanding Your Accounts
Investment Advisor Use of Social Media
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National Examination Risk Alert: Investment Adviser Use of Social Media
Compliance program related to social media:
Must comply with federal securities laws
Create specific policies
Identify risks and test procedures to effectively address risks
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SEC: Evaluate your compliance programs
Usage guidelines Define appropriate use of social media
Content Standards Examine risks pertaining to fiduciary responsibility for offering investment recommendations.
Monitoring Monitor firms social media sites and / or third party sites.
Frequency of Monitoring
Use risk-based approach to determine frequency of review. Consider third parties.
Approval of Content Consider pre-approval versus post review.
Firm Resources Are there enough dedicated compliance resources to adequately monitor activity?
Criteria for Participation
Analyze risk. Consider reputation of site, privacy policies, ability to remove third party posts, controls on anonymous posts, and advertising practices of social media sites.
Training Train IARs to promote compliance and prevent violations of federal securities laws and firm’s policies.
Certification Consider requiring certification by IARs to confirm compliance with social media policies and procedures.
Personal / Professional Sites
Adopt policies to address an IAR conducting business on personal or third party site, example, types of communications and content permitted (business card info v conducting business).
Functionality Examine functionality of each social media site, including privacy for clients.
Information Security Identify elevated information security risks associated with social media. Consider procedures to create firewalls between customer information, and firms’ proprietary information.
Enterprise Wide Sites Design policies to prevent advertising practices from violating Advisors Act
Issue Considerations
Source: SEC National Examination Risk Alert “Investment Adviser use of Social Media”, January 4, 2012
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Third Party Content and Testimonials
Rule 206(4)-1(a)(1) under the Investment Advisor Act prohibits testimonials
While not specifically defined, SEC staff interpretation of testimonial: “statement of a client’s experience with, or endorsement of, an investment advisor”
Use of “like” button could be a testimonial under the Advisor Act
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Record Keeping
Firms must develop policies that adhere to recordkeeping requirements set forth by the Rule 204-2 of the Advisors Act
Includes all written communications, including social media
Content is determinative
Must be retained and easily accessible for at least 5 years
Provide employee training
Check periodically that employees are complying
Index social media communications so a specific record is easily available
Use third parties to keep records
Key Legal Issues of Social Media
Privacy
Content Ownership
Intellectual Property Infringement
Unauthorized Activities
• Harassment
• Discrimination
• Unfair competition
• Defamation
• Confidential info
Regulatory Compliance
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Key Statutes for Operators and Users of Social Media Sites
Section 512(c) of the DMCA
Section 230 of the Communications
Decency Act
No statutory immunities for users
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Industry-Specific Legislation and Regulatory Bodies
GOVERNMENTFINRA
FINRA
SEC
GLBA
PCI DSS
ENERGY
FERC
NERC
GFTC
NFA
HEALTHCARE
HIPAAState of Oregon
Florida GRS
State of North Carolina
State of Massachusetts
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Cautionary Tales
Investscape, Inc.
Jenny Ta
Whole Foods Market
FedEx & Ketchum
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Pocket Slides: Case Studies
Outline Real Results
Case Study: RW Baird
LinkedIn Already Available to 1200
Veteran Advisers, tech savvy
Authentic Content
@MaryS_rwbaird
– 51 followers
– 93 Tweets (at the time)
– $1m prospect
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Outline Real Results
Case Study: Wealth Management Firm (NJ)
LinkedIn Only
Listening is Key, watching connections who matter
Using Social as an integral element of communications mix to spot change
LinkedIn Connection retirement status change = $2m account acquisition
– Job Change noticed on Status Update = 401k rollower
– FA obtains 400 new prospects in Energy market
– New Commercial Account Opportunity through colleagues LinkedIn Connections
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1200 Advisors live in 3 weeks!
Case Study: Raymond James
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Raymond James advisers will be able to share both approved firm content and their own ideas, which will initially go through a screening process before being posted to LinkedIn or Twitter“ .”
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Pocket Slides: Socialite Enable
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
Socialite Enable: Secure & Compliant use of Social Networks
Identity management Ensure that all the different logins of an individual link back to corporate identity
Activity control Posting of content allowed for marketing but read-only for everyone else
Granular application control Employees can access Facebook, but not Facebook Chat or Facebook Games
Anti-malware Protect network against hidden phishing or Trojan attacks
Data leak prevention Protect organization from employees disclosing sensitive information
Moderation Messages posted only upon approval by designated officer
Logging and archiving Log all content posted to social networks
Export of data Export stored data to any email archive or WORM storage
Issue Control Requirements
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Social Networking Widget Categorization
– Control access to individual social media sites
– Allow/block application widgets on popular sites
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Social Networking Feature Control
• Control features or areas of content posting by user or group• Patent pending DAY ZERO protection on new and changed
features
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Content Monitoring
Policy summaries
Easy-to-set policies– Archiving
– Moderation
Lexicons
Actions to take
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eDiscovery of Social Networking Posts
Social networking activity and posts are captured
All the captured events are presented for eDiscovery and available for export to archiving platforms
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Moderation
Posts to Twitter/Facebook/LinkedIn held for review by the following criteria:
– All
– Keyword/dictionary matches
– Regular expressions (e.g., credit card/SSN patterns)
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Moderator work queue & transcript review
Moderator queue allows bulk approve or each post reviewed individually.
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End User Experience
Toolbar displayed for each site, showing user’s post “queues”
User can click on their queues and see a list of the messages
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Pocket Slides: Socialite Engage
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
Socialite Engage: Activate Personal Brand
Socialite Engage helps Financial Advisors share relevant and pre-approved content, ensure authenticity of voice, measure impact and increase engagement to grow their business
The Socialite platform helps Financial Institutions protect brand and ensure compliance while allowing employees to share relevant content, measure impact and increase engagement
Socialite Engage: Activate Personal Brand
Content: Distribution of approved corporate content
Impact: Analyze and report on content performance
Network: Track aggregated engagement across social media
Key Contacts: Consolidated view of updates & interactions
Enterprise Integration: Integrate with backend platforms
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Focus on the Key Connections in your life..
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Content: CrowdSource Content that works
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Sharing, Integration, Results
Share pre-approved, relevant content
Content Engagement Analytics
Consolidated view of connections’ activities
Integration with backend platforms
Built-in compliance
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Analytics – Actionable results; measurable insight.
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Pocket Slides – The Social Universe
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
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Understanding the Social Landscape
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Pocket Slides: Services Available
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
Project Kick Off
Project Team Assigned
Project Plan Created and Approved
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Education and Training for Success
Week 1
Week 2
Week 3
Week 4
Week 5
Week 6
Policy Finalization
Education Content Tailoring
Training Review and Test
Stakeholder Workshop
Roll out Additional User Training
Review
Pilot Go Live
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Education and Training for Success
Role Based
– Admin / IT Policy Setting
– Compliance Reviewer
– Content Creator
– End User
Modality
– In person
– Web Conference
– Train the Trainer
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Education & Training Materials
User Guides (printed)– User Guides on each Actiance product
– Best practice approach documentation to Facebook, LinkedIn, Twitter (designed for regulated users)
– Success criteria for social media in Financial Services
– Guide to FINRA 10-06 and 11-39, Guide to IIROC, Guide to FSA
– Mapping Facebook, Linkedin and Twitter features to FINRA 10-06 and 11-39; IIROC; FSA, Global Social Compliance Requirements
– The human elements of social media how to overcome the issues
– Social Checklist for Financial services: What not to miss
– Legal Issues of Social Media
– Ediscovery Requirements of Social Media
– ROI of Social Media for Distributed Teams
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Education & Training Materials
Recorded Industry Training– SEC and Social Media – what this means to the firm,
the regulated individual
– FINRA and Social Media – what this means to the firm, the regulated individual
– FSA and Social Media – what this means to the firm, the regulated individual
– IIROC and Social Media – what this means to the firm, the regulated individual
– Legal Issues of Social Media
– Ediscovery Requirements of Social Media
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Education & Training Materials
Recorded Product Training– Using Socialite Engage
– Getting Started
– Content Creation
– Sharing Library Content
– Crowdsourcing Content
– What people want to read – when’s best to share
– How to organize my Key connections
– Engaging and Dealing with Feedback and Comments
– Measuring my results
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Legislative & Regulatory Environment Mapping
Statement of Work Identify scope of the legislative and regulatory environment that the community platform will cover.
Outline instances of legislation and regulation, with key elements relating the project.
Classify risks associated with specific regulations and legislation.
Outline key steps to take to mitigate risks related to the above (technical solution, policy, direction).
Notes: This piece of work is intended to provide high level guidance on the regulatory and legislative issues at play in
the formation of a virtual community, .hosted in the United Kingdom.
We will address applicable laws, regulation currently in place and also review upcoming requirements that may impact the community and the Bank.
Estimated delivery time Initial Draft: 3 weeks from confirmation of order.
Final Presentation & Report: 2 weeks from returned comments from draft.
Costs: $27,500. To include all research, reporting writing and in person presentation incorporating all comments and
updates from draft report.
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Thought Leadership Support & Guidance
Statement of Work Provide the Bank with thought leadership guidance based on worldwide trends in community usage and
management.
Provide the Bank with feedback and review on competitive organizations use of social collaboration platforms
Recommend enhancements, information navigation and content roadmaps, editorial and content.
Assist with engaging relevant content providers and nurturing clients on providing content.
Provide coaching on content and engagement – setting the tone, what’s working, how to get engagement
Identify other communities, networks and business applications to connect the community with
Deliver virtual and face to face social community best practice events for groups of clients (this can be virtual, with best practice speakers, either Actiance or other social though leaders engaged via Actiance)*
Estimated delivery time Can begin immediately. Suggest a formal kick off (face to face), with agreed (twice monthly) virtual meetings
to follow a set agenda, with adhoc content provided as appropriate
*Virtual and Face to Face Events for the Community’s use – not included in this cost, but suggested as an element to promote the ongoing growth and usage of the community.
Costs: $7,500 per month based on initial face to face meeting, twice monthly virtual meetings and face to face
meeting once every three months.
*Organizing best practice social community best practice events cost to be determined if requirement.
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Objective: Provide an overview of Social Media and how the regulatory environment affects use of such media by Financial Services Professionals
Knowledge transfer to include:– Review of applicable regulations and guidelines
– Supervision issues that need to be considered
– How rules map to each feature of the key social networks
– Discussion of best practices for compliance
Social Media Enablement for Financial Services
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Knowledge transfer to include:– Why is Social Media important?
– Social Media statistics
– Impact on mobile
– Why use Social Media?
– Facebook by the Numbers
– Success Stories for Facebook
– How do you do it? The 4 “E”s
– Create a Facebook Professional Page
– Establish a presence
Best Practices for Facebook
Objective: An interactive training workshop designed to enable effective use of Facebook
– Engage with customers and colleagues
– Prospect for new business/customers
– Update your status
– Educate and re-educate your network
– Expand your presence
– Do’s and Don’ts
– Measure your results
– Summary/Test/Evaluation
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Knowledge transfer to include:– Why is Social Media important?
– Social Media statistics
– Impact on mobile
– Why use Social Media?
– LinkedIn by the Numbers
– Success Stories for LinkedIn
– How do you do it? The 4 “E”s
– Create a LinkedIn Profile
– Establish a presence
Best Practices for LinkedIn
– Engage with customers and colleagues
– Prospect for new business/customers
– Update your status
– Educate (and re-educate) your network
– Expand your presence
– Do’s and Don’ts
– Measure your results
– Summary / Test
– Evaluation
Objective: An interactive training workshop designed to enable effective use of LinkedIn
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Knowledge transfer to include:– Why is Social Media important?
– Social Media statistics
– Impact on mobile
– Why use Social Media?
– Twitter by the Numbers
– Success Stories for Twitter
– How do you do it? The 4 “E”s
– Create a Twitter Profile
– Establish a presence
Best Practices for Twitter
– Engage with customers and colleagues
– Prospect for new business/customers
– Tweet / Retweet / Direct Message
– Educate (and re-educate) your network
– Expand your presence
– Do’s and Don’ts
– Measure your results
– Summary / Test
– Evaluation
Objective: An interactive training workshop designed to enable effective use of Twitter
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Objective: Provide a documented, end-to-end implementation of the Actiance Socialite technology
Knowledge transfer to include:– Overview of the Socialite solution
– Corporate LDAP Integration allowing policy creation based upon the customer’s requirements
– Extensive customized reporting
– Automated exporting to external archiving systems or enterprise content management systems
– Deployment options: SaaS, on-premise, or hybrid
– Licensing options for all methods
– Multi-network mapping functionality to ensure corporate user identity
– Integration with USG for complete end-to-end solution
Standard Socialite Overview, Planning, Configuration, and Implementation
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Pocket Slides: Explaining Deployment
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
Deployment Alternatives: User/Proxy vs. Page/API
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User/Proxy Approach– User traffic is routed through
Socialite – everything the USER does is managed
Pros
– Real time control
– Granular control over features & applications
Cons
– User must be on managed endpoint or network
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Deployment Alternatives: User/Proxy vs. Page/API
Pg 1
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Page/API Approach– Socialite monitors the
User/Company Page through network APIs
Pros
– Everything that happens on the target page is monitored & archived
Cons
– No control over feature/application access
– Potential window of vulnerability
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Profile Pre Approval Workflow
STEP 1User Creates Profile on LinkedIn
STEP 2Socialite intercepts changes and provides a notification that profile is being monitored and changes will only be made on approval
STEP 4• Reviewer signs-on to Socialite reviewer
console
• Reviewer reviews changes and Approves or Rejects them
• Reviewer also has an option to suggest changes
STEP 5User logins into LinkedIn and posts accepted changes
STEP 3Reviewer receives e-mail notification about pending changes
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Content Approval Workflow
STEP 1User posts message on Facebook,
LinkedIn, or Twitter
STEP 2Socialite intercepts post and provides a notification that content is being monitored and will be posted only upon approval by the moderator
STEP 4• Moderator signs-on to Socialite reviewer
console
• Moderator reviews messages and depending upon appropriateness Approves or Rejects a message
• Moderator also has an option to leave a review comment for each post
STEP 5Accepted posts are sent to the network on behalf of the user
STEP 6Accepted posts are viewed by the user
STEP 3Moderator receives e-mail notification about pending messages
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END
Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.
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