Social Media Recruiting: TMI (Part I)

How Recruiters Can Prevent Social Media Lawsuits (Part I)

According to a 2011 Society for Human Resource Management Survey on the topic of recruiting online only 18% of the companies surveyed use Social Networking sites to recruit talent. According to the Survey, “It appears that only a small number of organizations are using online search engines and social networking websites to screen job candidates. The primary reasons for not using these methods are the legal risks, the lack of verifiable data and the lack of the job-relatedness of much of the information found online.”

Although there are true benefits to recruiting online, namely access to a wider diverse talent database, efficiency in the computerized process of screening qualified candidates, reduced time-to-hire in a 24/7 search method and reduced recruiting costs, just to name a few, the “fear” of lawsuits is still holding companies back from using Social Media to assist them in recruitment. Why do employers think that Social Media is “riskier” than traditional recruitment methods? Because Social Media is “transparent” with information – or should I say, “TMI” (Too Much Information.) That is, the information that recruiters have long been trained to “avoid” such as not asking an employee how long he’s been married, or what church his family visits on Sundays, in order to avoid a claim of discrimination, is transparently glaring at the recruiter via the employee’s Social Networking profile.

The most obvious difference between recruiting talent online using Social Media sites, such as LinkedIn, and recruiting offline, using traditional means, such as newspaper advertisements for example, is the profile picture of the potential candidate that often accompanies their online site resumes. Why is the “picture” of a candidate or their “user profile” such a problem for recruiters now? Because the picture of your potential hire is worth a thousand words.

What is visible from a LinkedIn profile picture that gets a recruiter into legal trouble? From a single profile photograph, a recruiter can guess a candidate’s gender, national origin, age, race, color and ancestry, among other things. From a user profile, a recruiter can guess about marital status and sexual orientation. From Facebook Wall postings or other blog postings, a recruiter can guess religion, medical condition or disability, or even genetic information. In doing so, a recruiter is open to allegations that hiring decisions are based on “protected categories” that federal and some state laws, such as California, prohibit as categories that can be considered in making a hiring decision, including the recruitment process. Collectively, these anti-discrimination laws, including Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act of 1990, the Age Discrimination in Employment Act of 1967, the Equal Pay Act of 1963, the Rehabilitation Act of 1973, and the Genetic Information Nondisclosure Act of 2008, among others federal statutes as well as state statutes, including California's Fair Housing & Employment Act, and local ordinances, prohibit recruiters on behalf of the their employers from intentionally discriminating in the recruitment and hiring process.

For example, your company wants to recruit talent for an open Customer Service position and you have identified a hot-shot that seems perfectly qualified for the role. The hot-shot interviews throughout the company and seems a good fit until one manager informs you that she isn’t a “culture fit” because her LinkedIn profile shows she is a member of the Muslim Business Network group. Using this information as the basis for any employment decision, including the decision not to hire or recruit can get you and your company in legal hot water and violates the anti-discrimination statutes which prohibit discrimination on the basis of religion.

As a fun exercise, check out your own LinkedIn or Facebook profile and see how many protected categories you can infer. Someone recruiting me can identify from my LinkedIn profile and my linked blog entries information about my gender, my marital status, my national origin, my religion, my race, my sexual orientation and my age (from my year of graduation, not from my picture, which is ten years old.) What can I say? I haven’t looked that good since.

Moreover, these anti-discrimination statutes also prohibit recruiters from unintentional discrimination in the recruitment process by prohibiting conduct that creates a disparate impact on the workforce and is also not justified by a business necessity. The EEOC uses this example to explain disparate impact in recruitment: “An employer's reliance on word-of-mouth recruitment by its mostly Hispanic work force may violate the law if the result is that almost all new hires are Hispanic.” Disparate impact is a problem for recruiters using Social Media because of the transparency about these sites’ user’s demographic. For example, if your company chooses to only recruit talent through Twitter, posting tweets about open positions on your company’s Twitter profile, this can expose your company to a disparate impact claim. Quantcast.com has posted Twitter’s user’s demographics as 67% Caucasian and 3% Asian. An Asian applicant might argue that the recruitment process has a disparate impact on Asian applicants. Without a business justification for this, the company will be hard-pressed to demonstrate otherwise.

Certainly, one might think that the best way for a company to protect itself from a claim of intentional discrimination in the recruitment process is to outsource the recruitment process to a third party that will screen the applicants and eliminate or redact “protected category” information, thereby allowing the company to assert a defense if needed that it was not aware of the protected characteristics throughout the hiring process. This is, in fact, what many companies do. However, these are “best laid plans” because in reality, outsourced recruitment gives rise to additional statutory requirements, namely, compliance with the Fair Credit Reporting Act (FCRA) and its state statutory equivalents.

In June 2011 the Federal Trade Commission (FTC) published a blog article, ‘The Fair Credit Reporting Act & Social Media: What Businesses Should Know,’ which clearly stated that employers who use outsourced “Credit Reporting Agencies (CRAs)” are obligated to comply with FCRA. The FTC said, “Employment background checks can include information from a variety of sources: credit reports, employment and salary history, criminal records–and these days, even social media. But regardless of the type of information in a report you use when making hiring decisions, the rules are the same.” Therefore, the Companies providing reports to employers–and employers using reports–must comply with the Fair Credit Reporting Act.”

Certainly, handing over Social Media screening in recruitment to a third party may seem like the best way out of a discrimination allegation, but in doing so, you may be allowing the third party to substitute their judgment for yours. In a recent online Wall Street Journal article, Kim Harmer, a partner at Harmer Associates, a Chicago based recruiting firm, stated "I look at their Facebook and see how they approach what they put on it. Is it immature? Appropriate or inappropriate? I'm not judging their activity but looking at how they communicate what they do and their thoughts and their judgments to the public as a reflection of what they will do with clients and team members." Although the use of outsourced Social Media recruiting and screening agencies can allow an employer to filter out protected category information, ultimately, the employer is also taking a legal risk by putting their trust in another’s judgment to determine the criteria for screening out applicants and redacting information.

Of course, an obvious solution is to not screen applicant’s Social Media activity at all. Certainly, this is what the 82% of those surveyed by SHRM are thinking. Unfortunately, this also leaves an employer vulnerable legally. An employer who could have easily discovered an applicant was terminated for cyber-bullying his former coworker by simply viewing his public Facebook postings, may be accused of negligent hiring when that employee repeats this behavior after your company hires him.

So, what can employers do to avoid the double-edged sword of online recruitment? First, in order to avoid a claim of intentional discrimination, employers must be able to justify that the recruited employees are being recruited based on objective, measurable job related qualifications and that these are the only qualifications being considered. This is accomplished with a well designed job-description, carefully crafted interview questions that ask about job qualifications, not personal characteristics, and training everyone who interviews the applicant or meets the applicant about legal hiring practices and protected categories. If the employer outsources the Social Media screening process, a carefully designed list of sought-after qualifications should be designed by the employer so as not to “hand over” the process to a third party that may not understand your company’s needs. Finally, the employer must ensure that the third party recruiters are adhering to the credit reporting statutes, both state and federal throughout the process. If the process is not outsourced, it is wise to ask applicants to sign Social Media waivers anyway, thereby notifying them that their Social Media activity is being evaluated in the process.

It is not wise to require your applicants to give you their passwords to access their high privacy setting or “pretend-friend” them to see information you think they are hiding from you. The City of Bozeman, Montana required applicants to supply their username and password information to Social Media sites, but the public outcry against it made them curtail this practice. Whether unlawful or not, your company may run afoul of the Terms of Use of some Social Networking sites that prohibit sharing passwords or the Stored Communications Act by “asking” for passwords, as most employee-applicants will want the job so badly that they will “agree” without truly wanting to give you this information. Notwithstanding, surreptitious means for gaining information is never a good employment practice.

I know what you are thinking. What’s the point? If you tell them you are going to check their Social Media, then they will just clean it up or delete their drunken party twitpics. Now, how will you really know if your potential new-hire has a cocaine addiction or a penchant to bad-mouth his supervisors? But, the legal truth is, if you want to screen your potential employees, legally, without exposing yourself to increased liability, the only way to do it is to tell them you are going to do it, get their permission to do it, and then if something bad pops up, give them a chance to explain it. In the end, it isn’t about “catching” someone in the act of online foolishness, but about making sure that the person you hire is the “right” person for the job, based on the objective, qualifications of the job or based on the company’s stated goals and values.

In order to defeat a claim of disparate impact, the best practice is to diversify the online Social Media sites you use so that one site’s demographic profile does not define your recruitment strategy. Second, use an online aggregator, such as indeed.com or careerbuilder.com, which will aggregate from various Social Media sites. Third, compliment your online recruitment strategy with traditional means, such as paper postings, internal job postings, and college and university recruitment and job fairs. The more diversified your approach, the more diversified the pool of applicants. Thus, defeating a disparate impact claim.

It is a good practice to include offline recruitment as part of your recruiting strategy if for no other reason that some people do not have access to these sites or prefer not to participate in Social Networking or share information on the Internet, including their personal phone numbers, which would be something that one might include on a resume.

Certainly, if your decision to recruit online is based on reducing the costs of recruitment, implementing all of the above strategies will undermine this economic purpose. If that is your motive, than the best advice is to do your homework about the sites you choose to recruit from. Research and learn their user’s demographic. Make an informed decision based on the statistical information available to you. In other words, do not go blindly into the night of recruiting online. Know the publicly available demographic information of the sites you are using for recruitment purposes before they are used against you. Remember, that a business justification can defeat a disparate impact claim. If you need your new-hire to be bilingual in English and Spanish, it may be justifiable that you only posted the job on ihispano.com. Therefore, giving due consideration to the business justification for your open position is worth it. Another good idea is to always post and promote your company’s positions on your own company’s website. This will open the job to the entire web and defeat a claim that you limited the recruitment process based on protected categories. Finally, always include the fact that your company is an “equal opportunity employer” on all job postings. Thereby, encouraging all qualified applicants of any color, gender, religion, or condition to apply for the position.

Part II of this series will focus on Social Media Recruiting
Best Practices for Recruiters

Happy New Year! 2012 is going to be AMAZING! Thank you for your business, friendship, collegiality, and loyal support. I'm grateful beyond words!

Lead Your Industry By Preventing Slavery and Human Trafficking In the Supply Chain

On January 1, 2012, California’s Transparency in Supply Chains Act, (“SB 657”)
California Civil Code Section 1714.43(a) becomes effective.

This means that every “retail seller” and “manufacturer” “doing business” in California that has annual “gross receipts” in excess of $100 million (as of January 1, 2011) will need to:

1) To disclose to what extent, if any, it evaluates and addresses the risk of slavery and human trafficking in its products supply chain and whether a third party conducted the evaluation.

2) To disclose whether it audits its suppliers and whether the audits are independent and unannounced.

3) To disclose whether it requires its direct suppliers to certify that materials of the products comply with applicable laws on slavery and human trafficking.

4) To disclose whether it holds employees and suppliers accountable and if so, what the internal accountability standards are for employees or suppliers who fail to meet the standards.

5) To disclose whether it trains employees on mitigating the risk of slavery and human trafficking in the product supply chain.

The required disclosures must be posted on the company website with a conspicuous and easily understood link to the information on the homepage. (If the company does not have a website, a consumer must be provided the disclosures in writing within 30 days of requesting it.)

In the event that you might wonder how big an issue slavery and human trafficking is, here are some staggering statistics provided by CASTLA*:

· According to CIA estimates, as many as 15,000 to 17,500 men, women and children are trafficked into the United States every year.

· States such as California, Florida, New York, Nevada and Ohio are particularly vulnerable to human trafficking because of factors such as: proximity to international borders, number of ports and airports, significant immigrant population, and large economy that includes industries that attract forced labor.

· Los Angeles is one of the top three points of entry into this country for victims of slavery and trafficking. The diverse communities of this sprawling city make it easier to hide and move victims from place to place, making it very difficult for law enforcement to locate potential survivors.

· It is the fastest growing criminal enterprise in the 21st century – a nine billion dollar industry.

SB657 was enacted with the intent to inform consumers as to which companies are acting socially responsible so that consumers can choose not to patronize those that are not socially responsible, and to even the playing field for socially responsible companies that refuse to work with suppliers that use forced labor in competing against companies that have reduced costs because they do.

What is interesting about SB657, however, is what it does NOT do. It does NOT require anything beyond the disclosures set forth above. For example, a company can comply with the Act my stating that it has no policy regarding and does not monitor labor conditions involved in the production of its products or the materials incorporated in its products. It also does not have to actively ensure that its suppliers monitor labor conditions. Also, it does NOT apply to companies with annual gross receipts less than 100 million dollars. Last, it’s remedy for violating SB657 is an action by the State attorney general for injunctive relief. In other words, there is no financial penalty, which in itself undermines its “bite,” so to speak. (The Act does not limit remedies for other statutory violations that give private right of actions, injunctive relief, damages and attorneys fees.)

Despite these limitations, SB657 gives all companies that manufacture or sell products and their suppliers an opportunity to demonstrate leadership by going beyond the statutes disclosure requirements. Companies can “raise the bar” and act beyond the basic disclosure requirements of the statute. These “above and beyond” actions may include:

1) Raising awareness in the industry about slavery and human trafficking with press releases and PR campaigns that show their company's commitment to eradicating slavery and human trafficking.

2) Auditing the companies supply chain and ensuring that there are multiple avenues for employees to file grievances in the event that they are aware of unsafe work conditions, unfair labor practices and other conditions which give rise to human trafficking.

3) Training their suppliers about steps to take in preventing human trafficking and slavery in their countries and industries.

4) Refusing to do business with suppliers known for employing recruitment agencies that make the workers pay broker/agent/ recruitment fees or work visas.

5) Donating to nonprofits and organizations dedicated to eliminating human trafficking around the world.

Some online resources* on the topic include:

· Verite has a website, which is dedicated to stopping human trafficking and has many downloadable documents on topic.

· Apple has been transparent with its audit and report: It's audit was conducted a nongovernmental organization, Verite and the Fair Labor Association.

· The Human Rights Organization just put out a 2011 report.

Finally, companies that do not have to comply with the statute because they do not have receipts less than $100 million or do business in California can also take a stance against slavery and human trafficking thereby making them attractive as potential partners already in compliance to companies that are required to comply with it.

For companies that do not do business in California, note that on August 1, 2011 Rep. Carolyn Maloney (D-NY) introduced H.R. 2759, the Business Transparency on Trafficking and Slavery Act, a bill modeled after the California Transparency in Supply Chains Act. The bill would require companies to disclose efforts to identify and address the risks of human trafficking, forced labor, slavery, and the worst forms of child labor in their supply chains.

* I do not endorse or do business with any of these businesses or organizations.

I'm Perfect. Why Should I Change?

I’m Jewish. Shocking - a lawyer born Katz and married to a Pritikin, who knew? Being, Jewish, I have just come out of High Holiday services where I celebrated Rosh Hashanah, the Jewish New Year. One of the things we do on the New Year is reflect on the past year to determine what types of conduct or behavior we can improve upon for the next year. This is actually something that I feel is an important corporate lesson to pass on to the many Human Resource professionals who read my blog (thanks to all 7 of you.) It is also a good time of year, in September/October for this type of reflection, as opposed to January 1, the other New Year, because it is this final quarter when many of you are preparing your Proposals for Training to the budget committees or business group for approval. Keeping in mind that my business mission is to proactively prevent lawsuits, it is my opinion that two critical topics have been glossed over or absent from many companies training agendas: 1) Preventing Social Media Abuse and 2) Preventing Retaliation Lawsuits. I have blogged and taught on these topics in the past year a great deal in order to raise awareness to these two areas where I believe companies are increasingly vulnerable to related litigation yet corporations are doing the least to prevent them. Certainly, you may read my rationales for this bold assertion in my previous blogs on Social Media and Preventing Retaliation. In a nutshell, Social Media Abuse is the “smoking gun lawsuit” of the future and Retaliation lawsuits are the #1 claim being made in the nation.

Perhaps preventing lawsuits isn’t a good enough reason for you to change the stellar Training Budget or Proposal that you put together last year that you know will be approved if you only switch out 2011 for 2012. If that is what you have in mind, let me relay a humorous anecdote that the rabbi told during his service yesterday. He said a manager was upset that after 20 years of dedicated service to his company, he was passed over for promotion at his company. The promotion was given to another gentleman who had been with the company for only 5 years. When the 20-year veteran complained that he had more tenure and demanded to know why he was passed over, the HR professional responded that the young man was bringing more experience to the job. The veteran asked, “How can that be so?” The HR professional explained that the other man was bringing 5 years of experience to the role, while the veteran was merely bringing one year of experience that he had performed over and over again for 20 years. The morale of the story that the rabbi conveyed was that people need to continue to grow and learn, whether it be in life or their jobs. We need to continue to push ourselves each year to learn new skills and have new experiences, instead of repeating the status quo each year. I would add, that for HR professionals, the onus is on this department to ensure that all of your employees are given the opportunities for new growth through trainings on topics that are newly relevant and impactful, with follow up to ensure that the trainings are implemented or transferred down the line throughout the year.

In designing training proposals, keep this in mind. Ask, “What topics and skills do my managers want/ need to know about to help them “lead” employees best in next year?” One of the biggest gifts you can give managers is the peace of mind that they know the rules and laws so that they can manage their teams without the worry of being sued for their missteps. The two topics I think that are critical for 2012 are trainings that cover Preventing Retaliation Lawsuits and Social Media Abuse. Happy New Year.

Green Light, Yellow Light, Red Light

How to Abide by NLRB’s Social Media “Traffic Signals”

Social Media use is altering the employment law landscape in many ways, but the most recent trend is emerging from the National Labor Relations Boards (NLRB’s) aggressive protection over an employee’s right (whether the employee is a member of a union or not) to use social media sites as a venue for “protected concerted activity” as it is defined by Section 7 of the National Labor Relations Act (NLRA).

On this topic, two beneficial documents have been published recently to assist employers in drafting their social media policies and in navigating social media disciplinary decisions so that the employer does not violate the employee’s rights in this arena.

• On August 5, 2011, the United States Chamber of Commerce issued a helpful “Survey of Social Media Issues Before The NLRB” (“the Survey.”) The Chamber had sent a Freedom of Information Act request to the NLRB and received 129 cases back. According to Michael Eastman, the Executive Director of Labor Law Policy at the US Chamber of Commerce, “the issues most commonly raised in the cases before the Board allege that an employer has overbroad policies restricting employee use of social media or that an employer unlawfully discharged or disciplined one or more employees over contents of social media posts.
  
  
• On August 18, 2011, the NLRB’s Office of the General Counsel released its own Memorandum that summarized the most recent social media cases issued by the NLRB (“the Memorandum”.) In the Memorandum, Associate General Counsel, Anne Purcell, states, "Recent developments in the Office of the General Counsel have presented emerging issues concerning the protected and/or concerted nature of employees’ Facebook and Twitter postings, the coercive impact of a union’s Facebook and YouTube postings, and the lawfulness of employers’ social media policies and rules. This report discusses these cases, as well as a recent case involving an employer’s policy restricting employee contacts with the media."
  

From the Survey and the Memorandum employers can gain insight, not only into how to narrowly draft their own social media policies so that it does not prohibit conduct that might be “protected concerted activity,” but also how and when to discipline employees who violate their internal policy. Since I have previously blogged about essential provisions of a social media policy and provided my own Sample Social Media Policy (which carves out for Section 7 protected concerted activity) this entry will focus on employer's disciplinary decisions when an employee acts in contradiction to the company's social media policy.

Proactive Lawsuit Prevention Strategies for Social Media Abuse Related Disciplinary Actions

Although the Survey and Memorandum do not explicitly set forth clear rules for employers to abide by, employers can infer “Traffic Signals” from these documents to obey when determining how and when to discipline employees for social media use that undermines the employer’s interests. The traffic signals for employers are:

Red Light.
STOP employer. This is the instance when an employee is using social media in a way that may undermine or threaten the employer, but the employer should not discipline or terminate the employee for this social media use. Red Light employee actions exist when

1) the employee is using social media to create a site or page or use a site or page where the stated purpose is to organize his or her coworkers to join together to protest working conditions or vote in a union.

2) the employee is using its own social media site or page to complain about wages, working conditions, or management and he or she is explicitly asking other employees for their opinions and support and/or other employees are giving their opinion and support about the working conditions at that company.

3) the employee is using social media to whistle-blow the employer’s illegal activity.

Yellow Light

SLOW DOWN employer. This is the instance when an employee is using social media in a way that may undermine or threaten the employer, but the employer should proceed with caution, and hopefully seek legal advice, before it makes a decision to discipline or terminate this employee for this social media use. Yellow Light employee actions exist when

1) the employee is “venting” about his/her own work, working conditions, wages or manager, but he/she is not seeking support from coworkers, yet other coworkers are commenting on it and/or “liking” the comment.

2) The employee is “griping” about work, working conditions and wages, in general, or management, but no one is commenting about it, although the employee’s friends or followers include his/her coworkers.

3) the employee is using social media to “out” the employer or managers for what the employee erroneously perceives as illegal or unethical activity.

4) the employee is name calling or bad-mouthing the company or its employees, but the comments are all true and not harassing or discriminatory

Green Light
INVESTIGATE, BUT DISCIPLINE ACCORDINGLY employer. Assuming the following activities are appropriately investigated and also prohibited by the company’s policies, if the employer determines that the employee is engaging in the following activities while using social media, the employer should discipline the employee for violating the company’s social media policy. Green Light employee actions exist when

1) the employee is posting violent threats, harassing and/or discriminatory comments about his coworkers, managers or customers and the comments unreasonably interfere with the targets ability to perform his/her job, especially when it is clear that these comments have nothing to do with working conditions.

2) the employee is posting comments that are so disloyal, reckless, or maliciously untrue about the company, and the company can prove the employee knew this when he/she posted it.

3) the employee is disclosing the company’s trade secrets and/or confidential information.

4) the employee is spending so much time on social media during work hours that it is interfering with the performance of his or her job (but remember to enforce this policy consistently.)

5) the employee is expressing a personal vendetta or gripe about his/her manager or coworkers, but it is not directed at coworkers and only his family and friends see it.

Remember, bad words or profanity are not determinative. It is about the motive behind the name-calling that the NLRB cares about. Also, how the company learned about the social media abuse will be taken into account. In other words, employers should not force employees into giving up their passwords to privacy protected groups or chatrooms. (See Pietrylo v. Hillstone Restaurant Group.) Also, do not pretend to be someone you are not to trick the employee into “friending” you or “accepting” you, especially if you are an attorney-investigator as this may be in violation of your code of professional conduct. Finally, using unlawful surveillance, interrogation or threats to get information about an employee’s social media postings violates California’s and other state statutes, which protect employees from this conduct.

Last, recognize that these “Traffic Signals” are merely my interpretation of the Survey and the Memorandum at this moment in time and the interpretation may change as the laws and rules surrounding social media use are in constant motion and continually change based on new cases and emerging law.

Similar Posts:

Elvis Has Left the Building

Social NOTworking PIHRA Meetings

It's Business, Not Personal

To Facebook or Not to Facebook

Do You Know Where Your Glass Slipper Is?

Retaliation Prevention Policy Must-Have Provisions
I am looking forward to my upcoming NEW program for PIHRA's 2011 Annual Conference. It isn't too late to register. I am speaking on 2 topics: Social NOTworking and also Retaliation: Shoulda Put A Ring On It.

What I learned in researching the latter topic, is that Retaliation Prevention Policies have a Cinderella complex in most companies. The employers expect it to do all the work, by protecting it against retaliation claims, but they don't give it any glory. That means, that much like Cinderella's mean step mother expected her to keep things tidy, but didn't let her go to the ball, Retaliation Policies are usually buried deep inside a company's handbook, in two sentences at the end of the Harassment Prevention Policy. The company expects them to protect it from lawsuits, but doesn't highlight it as a stand alone policy, the way it should.

The fact is, now that Retaliation Lawsuits are the #1 Equal Employment Opportunity Commission claim, Cinderella need a new dress, new shoes and a white coach to take her to the ball. The bottom line is that Retaliation Prevention needs to take the center stage. In order for an employer to effectively prevent Retaliation claims and protect itself from Retaliation lawsuits, it needs a stand alone, detailed Retaliation Prevention Policy.

The Retaliation Prevention Policy should have the following iron-clad provisions:
1) It should make a stand alone commitment to a Retaliation-free workplace.
2) It should define Retaliation
3) It should give examples of Retaliatory conduct
4) It should set forth a complaint procedure
5) It should provide alternative means for making complaints
6) It should not promise confidentiality
7) It should set forth the consequences for retaliatory conduct

Here is my new Sample Retaliation Prevention Policy.* Hope to see you at the conference.

*This sample policy is not intended to be "ready for use." In addition, it is not to be construed as legal advice. I strongly encourage you to consult with a labor/employment attorney or contact me prior to using these forms within your company to ensure compliance.

Other blogs on topic: He's Just Not That Into You

Social NOTworking PIHRA District Meetings

I am looking forward to presenting Social NOTworking to PIHRA Districts 19,12 & 1 in the next few weeks. In anticipation, here is my Sample Social Media Policy* and a link to a great article by CNN Money showing examples of Social Media abuse, entitled "6 All Time Favorite Social Media Screw Ups." If you plan on attending the meetings, you can anticipate learning the Proactive Lawsuit Prevention Strategies to implement to prevent "screw ups" from happening at your company? I'll give you a hint. "Choo Choo The Train Stops Here." See you soon.

Related Posts: It's Business Not Personal, To Facebook Or Not To Facebook, Elvis Has Left the Building

* The samples are not intended to be "ready for use" by readers. In addition, they are not to be construed as legal advice. Rather, these forms are intended as samples and should be adapted to your particular company's needs. Although this work is copyrighted, you may freely use the content in creating or changing your own forms. I strongly encourage you to consult with a labor/employment attorney or contact me prior to using these forms within your company to ensure compliance.