Compliance Archiving for Social Media

Overview

For businesses, social media is a powerful way to connect. Services like LinkedIn, Twitter and Facebook can deliver significant business value when connecting with clients, partners and colleagues. In the financial industry, the specific requirements of regulators like the SEC and FINRA can present a challenge — how can firms take advantage of social media while remaining compliant?

Compliant social media is the responsibility of every firm. Like other forms of electronic communication, social media is subject to SEC and FINRA compliance requirements. However, regulatory bodies have not issued new guidelines for each individual type of social media communication. Rather, social media fits into the framework of existing SEC and FINRA Rules. For example, FINRA Notice 10-06 (dated January 2010) advises that firms must ensure they have a solution in place to retain all records of social media communications as per SEC Rules 17a-3 and 17a-4 and NASD Rule 3110.

Social Media Archiving: for compliance and security. Secure, automatic social media archiving is the solution to meeting compliance requirements for all types of electronic messaging - including social media messages. Capturing a permanent record of every communication is essential to preventing data leaks and lost messages. It is also crucial to ensuring your firm's preparedness for audits, eDiscovery requests and legal proceedings.

Global Relay Archive for Social Media is purpose-designed for compliance - it securely captures, indexes and archives social media messages from LinkedIn, Twitter and Facebook. Global Relay Search provides the ability to search archived messages, allowing you to quickly and easily retrieve any past conversation. With Global Relay Archive, social media messages are integrated into a single unified archive of all your firm's messages, along with email, instant messages, BlackBerry, Bloomberg, Thomson Reuters and multiple other communication types. This simplifies your firm's compliance review process - Compliance, Legal and HR departments can use Global Relay's powerful suite of compliance review tools to perform monitoring and supervision across every message type, including social media.

Benefits

One vendor — Global Relay provides a single end-to-end solution for social media capture, indexing, archiving, supervision, audit and eDiscovery. Since Global Relay Archive supports social media seamlessly, the need to manage a third-party social media solution in addition to your existing archive is eliminated.

Comprehensive Data Capture — Once a social media account is set up for archiving with Global Relay, the user's activity is captured no matter what location or device they may be using. Unlike proxy/middleware solutions, Global Relay captures social media content generated on home PCs, mobile devices, etc.

Seamless setup — All Global Relay solutions are quick and easy to enable at your firm. Once the system is set up, users' experiences on social media are not affected.

Which Regulations Apply?

Registered financial firms are responsible for ensuring their social media activities are compliant with regulatory requirements, including:

  • SEC 17a-3, SEC 17a-4, NASD 3110 — Requirements for electronic message recordkeeping
  • SEC Rules 204-2, 206(4)-7 — Requirements for message recordkeeping & supervision
  • NASD 3010 — Firms must establish and enforce written procedures for communications
  • NASD 2310 — Financial recommendations made to a specific investor must be suitable for that investor
  • NASD 2711(b)(3)(A), NYSE 472(b)(3) — Firms' legal & compliance departments must be copied on communications about research report contents
  • FINRA Notices 10-06, 11-39 — Added guidance on blogs and social media web sites
  • Additional rules and regulations may apply — Depending on the nature and purpose of the social media communication at hand

Social Media Compliance Partners

Added control via Global Relay Social Media Compliance Partners. Through trusted technology partners, Global Relay also offers additional capabilities for more precise control over your firm's social networking activity. These capabilities help support and enforce your firm's social media policies.

  • Pre-review functionality - the ability to require firm principals, Compliance Officers or Legal departments to moderate specific types of social media content before it is visible to the public. With this feature, certain types of social media content is added to a queue for supervisor review before being posted on LinkedIn, Twitter or Facebook. This pre-review functionality is a FINRA compliance requirement for social media content that is deemed "advertisements" - such as public profiles and posts.

  • Feature-specific Application Controls - features to block specific aspects of social media sites. If certain aspects of LinkedIn, Twitter or Facebook (for example, Facebook Games) are not essential for your firm's business, they can be restricted.

  • Employee-specific Access Controls - controls to customize social media access levels for specific users. With this feature, you decide how much access to grant each employee on LinkedIn, Twitter and Facebook. For example, administrative staff might be granted only read-only access to social media sites, but registered representatives have the right to post content and status updates.

Global Relay Archive for LinkedIn

LinkedIn Global Relay brings compliance to the LinkedIn community.
Developed in partnership with LinkedIn, Global Relay Archive for LinkedIn is an in-house built solution that enables your firm to leverage the LinkedIn community while meeting the regulatory requirements for recordkeeping and supervision of electronic messaging found in the financial industry and other sectors. It is simple to setup and works automatically in the background to capture your firm's LinkedIn communications.

Once an employee's account is selected for monitoring, LinkedIn messaging is captured and archived no matter where employees are or what device they use to access LinkedIn (iPhone, BlackBerry, iPad, home PC, etc.).

LinkedIn

Global Relay Archive for LinkedIn captures, indexes, and stores every type of messaging within LinkedIn including: Messages, Invitations, InMail, Profiles, Network Updates, Comments, and more.

Global Relay Archive is connected to the LinkedIn API. Whenever there is new messaging content generated within a user's LinkedIn account, that content is downloaded and ingested into Global Relay Archive. As an evolving service, LinkedIn consistently adds features and modifications to the way its system works. Since Global Relay Archive connects directly to LinkedIn via API, the archiving of messaging is never disrupted by these changes.