Roche Publishes Social Media Principles

Directions
 The wrestling match in the development of social media guidelines is not confined to the health care industry, but as a highly regulated sector, there are some serious considerations for companies vis a vis social media.  Direction is hard to find.  

The approach some companies take to social media in the workplace is to try to ban it, which for a number of reasons is not very practical, but especially since increasing numbers of people access the Internet through mobile devices.  They don't need your stinkin' computer to access social media.  

The opposite tack is to develop some guidelines or principles that will help guide staff.  Today Roche published their own Social Media Principles to help guide staff in the use of new and emerging media, which are downloadable and public.

In laying out ground rule, which are pretty common sense rules, the company also makes the point that cannot be made too often… "Always remember that engaging in social media is not a one-off activity."  What is the long-term concept:  who do you want to engage with, for what aim and result, what are the opportunities and risks?"

I would actually say that is true not only for social media, but for all forms of communications that seek to engage specific target audiences.

The Roche Social Media Principles are not a stand-alone document.  Roche has apparently already done some work in developing a Group Code of Conduct and an overall Communications Policy.  The social media principles incorporate those guidelines by reference and then outline separate rules for online activities – a set of 7 for personal activities and 7 for professional activities. The company provides more than a list, but also provides rationale, explanation and example for each.  The principles are both concise and to the point and are not complex in the least.  

One of the things I liked the best, however, was the fact that under the About Roche tab one could navigate one's way to a page that is exclusively about Roche's social media activities.  There one can see them subdivided into corporate activities, local activities and branded activities.  I love organization.

The publication of such guidelines is a noteworthy development.  Now if we could only get the FDA to do the same.  

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One Response to Roche Publishes Social Media Principles

  1. Arnold I. Friede says:

    My own “take”, for what little it may be worth, is that the Roche Principles are at such a high level of generality that they are not particularly helpful in day-to-day dealings. For example, it suggests that employees can speak “about Roche” in some kind of “personal capacity”, even if they are not speaking “for Roche” without providing clear groundrules about the permissible content of these communications. I submit that Roche employees, who are encouraged by the company to speak “about Roche” may be effectively acting as “agents” of the company and that their communications may be ascribed to the company for regulatory, legal, and other purposes. Absent clear rules about what things may be discussed, by whom, and how, I think the Roche Principles, while perhaps a “nice touch” from a PR/perception-of-transparency perspective, create more problems than they solve. I think that the reference in the Roche Principles to existing codes of conduct and standards are likewise “nice” but not too helpful in practice. There is way too much liability associated with company employees, who are encouraged by the company to speak on-line “about Roche” engaging in a variety of unmonitored and largely uncontrolled behavior that no one is even affirmatively monitoring. My own sense of all of this is that, to the extent pharma/biotech companies encourage engagement on-line, they need to be very clear on who has the authority and responsibility to speak “about the company” on line. Put differently, I have the strong sense that companies should not encourage open-ended dialogue “about the company” by any and every employee. This doesn’t mean companies should squelch speech by their employees. It simply means that, from my vantage point, companies should endeavor to control who is and is not authorized to speak both “for the company” and “about the company” on-line. If others do it, so be it. But at least there is a line in the sand and some control mechanism in place about who can do what to whom and when.
    ARNIE FRIEDE
    Arnie@FriedeFDALaw.com