If you are having important business conversations on social media, find and implement the tools that will enable and support you to continue to do that, uninterrupted.
Brolly team
5 November 2020
This article first appeared in the November edition of the RIMPA quarterly magazine IQ.
In 2019 and 2020 Telstra has been broadcasting a series of advertisements featuring heartwarming stories of connection. We saw a couple calling to tell their parents they were engaged, a nanna in lockdown connecting with her daughter and granddaughter, and a farmer with his ute propped on a boulder, trying to call his wife from a phone with no signal.
The tagline “You don’t need Australia’s best network… until you do” is reminding us to choose the right tools and platforms to support the conversations we want to have.
It seems timely to think about choosing the right platforms in the context of business and government use of social media. As Covid-19 lockdowns have forced Australians to transition their workplaces out of office blocks and into home offices, reliance on social media as a way to provide customer service and community connection has also grown.
Admittedly, these trends were already underway before Covid-19. In data released by We Are Social, Hootsuite and Global Web Index in February 2020 the number of social media users in Australia had increased by 735 thousand (+4.3%) between April 2019 and January 2020.
In their April 2020 report analysing the impact of Covid-19 on our online activities, the same researchers reported that 23% of people surveyed were spending significantly more time on social media.
In line with this trend, government and business have embraced and amplified their use of social media as a key channel for conversations with customers, during these times of change.
For many the virus has simply accelerated a digital transformation journey that was already underway, including a widespread adoption of cloud services like Microsoft 365, and a speedy expansion of social media’s role in the communications mix.
However, there’s a risk that this speedy adoption and a focus on the convenience and ease of use commands a high price. With social media, the price is compliance at best, and potentially much, much more.
For social media specifically, there is a huge risk associated with relying on third parties like Facebook and Twitter to take care of your records, while your social media and service teams are getting on with serving and communicating with customers.
To be clear, if the only place you’re keeping your social media records is in the platform where they are published, you’d be well advised to read the respective terms of service of providers such as Twitter, Facebook and Instagram.
You may be alarmed to read that it might only take a policy change, an outage or a hack for you to lose your precious records. And have you considered where this data is housed? If you needed to access those records, could you?
National Archives Australia (NAA) provides clear guidance on this: “Social media records held in their native applications on third-party sites may not be legally regarded as a Commonwealth record. Despite being created by an Australian Government agency, the information may not be able to be retained or accessed over the long term.”
Subtext: You’d be well advised to archive your social media records, and to ensure the archived records are housed in Australia.
Social media can bring out some strong views.The 2020 Yellow Social media report reveals that 33% of surveyed business respondents were frustrated by the need to manage negativity and trolls on their socials. Anecdotally, the customers I speak to regularly at Brolly tell me that they’re seeing more hate, profanity and negativity side-by-side with all the good conversations they’re having. In the face of this bad behaviour, social media teams may choose to delete offensive material from social media accounts to protect the organisation’s brand and reputation.
While individual policies vary, most social media teams have clear guidelines for when a post can be deleted. The problem arises when you delete a post that should have been retained for recordkeeping compliance. On Facebook, Twitter, Instagram, LinkedIn or any other platform if you delete a record, it’s gone forever, along with all its context – the metadata, media, links and other data that give a post its meaning from an information management point of view.
For government agencies using social media to interact with Australians, the deleted item was a public record, and should have been retained and classified, and have its retention and disposal guided by an RDA (Retention and Disposal Authority). And for other regulated sectors, similar requirements will apply.
Bottom line, you may be required by law to archive your social media records. The exact approach will depend on how your organisation is using social media. Government agencies, records management experts like Miktysh and social media management platforms like Hootsuite are working alongside specialist archiving services like Brolly to address the evolving questions raised by the need to effectively capture and manage this type of digital data.
The NAA again: “If your agency uses social media for business activities, the information created is an Australian Government record and needs to be managed.”
When researching State and Territory guidance to State government agencies, all have minor variations on a shared theme.
While not specifically referencing social media, the Guideline to Principle 5: Protect Principle states “ACT Government organisations must secure, store and preserve of records, information and data to protect the interests of the organisation and the rights of employees, clients, stakeholders and citizens, now and into the future.” while quoting the Territory Records Act 2002 definition of a record as “information created and kept, or received and kept, as evidence and information by a person in accordance with a legal obligation or in the course of conducting business”.
“Records and information generated through social media can provide value to business and the community and should therefore be well managed in order to maximise this value. Social media use by government is also subject to community expectations and legislative requirements for the appropriate management of information.”
“A record is a piece of information which has been created or used by a PSO [Public Service Officer] to come to a decision, formulate advice, conduct a transaction, or in some way document government business.”
“An agency should consider how it manages any official records created during the use of the social media service. This includes recording any decisions made or transactions undertaken with individuals via the social media service.“
“Information about government business is increasingly located in social systems. If this information is needed by your organisation to help perform, improve or report on its operations, then you will need information management strategies to support your social media business.”
“Social media posts are records when [they are] created or received by a public officer in the course of their duties are evidence of government business. They document the actions taken by public officers and should be managed as a record for reasons of accountability and transparency.”
“Any business-related content created by a government organization using social media is subject to the same recordkeeping requirements as information created by other means. Whilst some posts will be ephemeral in nature, or duplicate content from elsewhere, other posts may form part of the organization’s business activities and will need to be kept accordingly.”
As Michael Sloman from Miktysh noted in his article in idm magazine last year, the decision about which social media interactions to keep can seem confusing.
Perhaps it is helpful to think about the risks that exist in the world of social media as a starting point, to guide a strategy that goes beyond compliance for what needs to be protected and why.
Social media channels appear in the news from time to time, as hackers delight in breaking in and wreaking havoc. The July 2020 Twitter Hack is a recent example. If the worst were to happen and your social media accounts were hacked by someone who decided to delete posts or comments you’d created, an archive would at least give you a record of what you’d published, and what had been deleted.
Risk assessments, business continuity planning and communications audits are part of life for any large organisation’s ongoing existence. As leadership teams become more aware of the value of social media as a key communications channel, it will be natural to have social media records included in audit programs.
We’ve already seen a number of inquiries out of Covid-19. There will inevitably be more. If your government agency or other organisation has been engaging customers or citizens with content that needs to be called into evidence, the ability to export true records of your social media activity will minimise the disruption that these kinds of requests can cause.
The website of the Office of the Australian Information Commissioner (OAIC) is very clear about the rights of Australian citizens to access government documents:
“The Freedom of Information Act 1982 (FOI Act) provides a legally enforceable right of access to government documents. It applies to Australian Government ministers and most agencies, although the obligations of agencies and ministers are different.”
What that means in practical terms depends on the way the organisation or individual uses social media but again, the core principles are around transparency and access, and the rights of the requestor.
While rarely the domain of records managers, brand and reputation are key for the social media team. An archive provides a safety net for social media managers, giving them confidence to manage their conversations on social media, knowing that a deletion or edit that’s necessary to protect the organisation’s brand will not contravene any recordkeeping regulations.
The compliance landscape for social media recordkeeping in Australia is evolving. Jurisdictions such as the USA and Europe are also grappling with these questions, and at Brolly we’re watching closely. Even though the current guidance from Australian government records agencies sometimes seems vague or non-committal, as archiving and records management authorities improve their understanding of this space we can expect that the guiding principles of public access and transparency will remain at the core of emerging regulations.
Industry sectors are also increasingly aware of their obligations in this area. For example, we can expect that regulations such as Dodd-Frank (USA) and EMIR (Europe) for financial services sector will address social media in detail at some point, and that Australian regulations will also have an equivalent focus.
We will continue to see that Government agencies and regulated industry sectors using social media to do business will be mandated to find efficient ways to capture, preserve and protect their social media records, so that they comply with privacy legislation and can also be appropriately accessed as required.
Circling back to the Telstra ad campaign, the next step for government agencies and businesses in regulated industries is straightforward.
If you are having important [business] conversations on social media, find and implement the tools that will enable and support you to continue to do that, uninterrupted.
Be ready to have those records called upon for legitimate and appropriate reasons. Start archiving efficiently so that your social media teams and your record management team share an understanding of why archiving social media is important, and how to make it part of your day-to-day.
Talk to a social media archiving specialist, and keep the important conversations going.
This article was written by the team at Brolly. We’re a creative bunch, and we love social media archiving. Like most of the things we do here, this article was crafted with care and attention to detail. If you spot an error, or want to know more, don’t be afraid to reach out and say hello. We’d love to hear from you.
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