Organizational Internal Controls for Social Media
By Jim Kaplan, AuditNet.org
As online social media continue to gain
mainstream acceptance, traditional face-to-face
contact is taking a back seat as the networking
method of choice. Facebook, Twitter and LinkedIn
are gradually changing the protocol of how
businesses and professionals operate.
In the past, for someone to do the bulk of their
communication online would have been unusual,
whereas now that is the norm. Everyone is
e-mailing, blogging, using wikis or all of the
above to give their business a boost. It is a
paradigm shift that has brought with it new
demands on building an internal control
environment that specifically addresses the
social media process.
The lines are not clearly drawn. While some
individuals insist social media is the way they
communicate only for non-business purposes, it
is making inroads in the business community.
(There is a generational gap that is causing the
perfect storm where technology clashes head-on
with a cultural phenomenon). The reality is that
sometimes business and non-business
communications mingle.
Since social media is still evolving, many
organizations have yet to provide direction or
develop policies on its use. Employees
themselves are often unsure (from a business
perspective) about the generally accepted rules
of online behavior.
Some forward-thinking organizations are building
social communications into their policies and
procedures, but many are still trying to
navigate the uncharted waters to reconcile the
new avenues with organizational policies. Those
policies relate to ethics and behavioral aspects
of communicating – not only within the
organization among employees and supervisors,
but also externally with vendors and customers.
Social media controls are becoming more
important for audit organizations to address.
They cross different lines, dealing with IT
systems and tools like the Internet, blogging
and various software applications that
individuals use to access social media.
What Policies Should Govern These Tools?
Some companies, like IBM, have developed social
media and computer policies. In addition, many
high-tech firms, like Microsoft and other
software and Internet-based businesses, are on
the forefront in recognizing social media as a
phenomenon that is here to stay. Organizations
will have to change the way they try to control
this new communication mode.
In this context, performing a risk assessment
might be the first order of the day. What
strategy does an organization have that applies
to social networking? Will it continue to allow
employees to access social networks in the
office or block them? Will it implement policies
whereby corporate resources are restricted from
social networking possibilities?
There is a real push and shove between different
departments within an organization: marketing
relishes signing on to Facebook, Twitter and its
kin to disseminate information and reach
customers. But auditors are looking at it and
asking: What kind of risk does this expose our
organization to? And it is not just IT risk, but
possible risk to plagiarism, sharing of
information, legal liability and intellectual
property (employees giving away corporate
secretes). Reputation risk, too, is a big
concern.
Most organizations have some type of network oversight capability so they can monitor activity. But this becomes a privacy issue; and if an organization is going to do this, it needs to be consistent and have a specific policy defining what is acceptable behavior on the part of an employee. It also must inform employees that their online activities will be subject to scrutiny.
Another issue many communicators today disregard is the permanence of the internet. For example, pictures posted during college years relating to offensive behavior, whether they depict drinking or sexual activity, have a way of coming back to haunt. One thing I recommend is keeping one’s business contacts separate from social contacts; never mix the two. Do not post anything on the internet that you would not want your parents (or future employer) to see!
It behooves an organization to have a policy in place whereby it is monitoring network activity and checking to see whether employees are violating their own internal rules regarding communication. Furthermore, to avoid legal liability, companies should treat all employees equally. The tone at the top must send a clear message about proper social networking behavior just as it does on fraud and ethics.
When it comes to social media, a number of IT controls need to be in place (e.g., protection that guards against viruses on an organization’s network). Employee productivity is another social networking issue; although I do not view it differently from an employee’s personal use of the telephone or surfing on the internet. You cannot enforce a policy prohibiting employees from using the phone. Also, keep in mind that once employees leave the office, they are on their own. Potential risk is magnified, especially if they make references to their employer in their personal communications.
Once individuals start using Twitter and similar applications, they tend to view them as channels for outbound communication. The reality is that when this type of communication is initiated, it provides a gateway in, which is why many organizations, concerned about vulnerability, are blocking social media traffic and social media sites.
I have yet to encounter an organization that is auditing internal controls on social media. Typically, auditors first need to understand the technology. That is what they are doing now as they look at threat potential: whether the risks are high, medium or low and what sort of associated risks might be lurking on the sidelines. Then they can move to the next step and perform a risk assessment of the entire social media issue.
Accordingly, I think auditors will start developing ways to audit social networks based on:
- Level of risk assessment
- The organization’s compliance and non-compliance with policies and procedures
- Soft controls in place from an ethical standpoint
- The top-down organizational tone
Looking ahead, during the next two or three years, this is an area where audit departments will develop programs to audit social networking and the inherent risk they expose to an organization. This link provides guidance and examples from many well-known organizations on establishing social media principles and policies. For further details visit www.socialmediagovernance.com.
About the Author
Jim Kaplan, Founder and CEO of AuditNet®, the
global resource for auditors, is an Internet for
auditors pioneer. As the founder and principal
of AuditNet®, he developed an internet website
that links auditors around the world with over
1,300 audit-related resources and over 2,000
audit work programs. The AuditNet® website
www.auditnet.org is used by auditors at
Fortune 500 companies, public and private
companies, government agencies, and
organizations around the world searching for
audit-related information. This article is a
natural outgrowth of his original idea of
developing an online information network for
auditors. Jim can be reached at
info@auditnet.org.
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According to a recent poll conducted by Protiviti KnowledgeLeader
Does your organization have a
formal policy in place focused on the use of social media in the
workplace?
Yes 33.3%
No 61.5%
NA 5.1%
Final poll results
The opinions, beliefs and viewpoints expressed by the various authors and forum participants on this web site do not necessarily reflect the opinions, beliefs and viewpoints of AuditNet®


