I heard this week, probably some time after everyone else, that the Australian Securities and Investment Commission (ASIC) has released a discussion paper on guidelines that could apply to the use of social media by the financial services sector. I have to say a 'discussion paper' on social media sounds like something of a paradox. Why not just start up the discussion on a Facebook page (yep. ASIC is on FB) or have a crack at opening up discussion on Twitter? It might cast a light on some of the challenges we face!
I have to ask is there any point to a discussion paper on social media? Isn't this a bit piecemeal? As communications strategists, we don't consider social media in isolation, but part of a multi-channel, organic whole. So why would a regulator not consider a review of the entire disclosure regime with social media included as an integrated component?
To consider it alone is like the discussion that led to Product Disclosure Statements. Why wasn't incorporation by reference to website information integrated into the PDS discussion in the first place, rather than having PDSs considered as a stand-alone communication? Let's face it, the Financial Services Reform Act became effective from 10 March 2004 (who thought of that date), by which time we all had websites.
There's no doubt that the industry needs guidelines on social media's fit into the regulatory matrix. The disclosure requirements for the financial services sector are outdated by virtue of being geared to print media and, to some degree, traditional websites. Try putting full disclaimer into 140 characters on Twitter! What about throwing a few extra lines of disclaimer in an SMS? Users will not tolerate it.
The biggest challenge for social media integration is not disclosure, but engagement in two-way conversations. What are the rules around archiving? Is there any need to archive? How can social media conversations be captured and interfaced with more traditional communications channels such as call centres? Imagine a call centre employee picking up a call from a customer who claims to have just been 'speaking' with someone from your organisation on Twitter. What evidence does that operator have of promises made, advice given and so on?
These are questions that must be answered before social media can be fully integrated into wider communications and engagement strategies. Until then, we've only got a toe in the edge of the pond. One-way, outbound conversations will not deliver desired outcomes in the social media space.
However, I believe that any brand-conscious business should not be relying on the regulators to answer these questions. It is in the best interest of effective and rewarding customer relations that organisations answer these challenges. As usual regulation is only required to look after the interests of consumers potentially exposed to unscrupulous operators.
Will consideration of appropriate social media regulations provide new perspectives on those we already have for more traditional channels and produce overall improvement in communications? I fear that by considering social media as yet another stand-alone channel, we could just add an overlay of unique regulations or amendments that will further complicate an already muddy customer interface. It would be much better to launch a more holistic discussion of communications channels.