November 25, 2013
We just returned from the Financial Services track at Dreamforce, where many speakers touched on the topic of Archiving for Chatter – and its potential regulatory implications. This led to many interesting discussions at our booth, with some of the common themes and conclusions summarized here.
- The most frequently asked question/comment: “We would like to enable Salesforce Chatter, but our compliance team is concerned about the implications. What can we do?” Not surprisingly, many of the Dreamforce attendees we talked to had recognized the business value of leveraging their investment in SFDC to drive collaboration and productivity via Chatter (or, perhaps, are being pressured by SF users to enable this feature). The reasons are clear within financial services: enabling better customer service, improving communication flow with independent agents, and in sharing account information with peers. But, simply turning that feature on led many into conversations about internal policies pertaining to social media, supervisory obligations addressed under FINRA’s 11-39 guidance on social media, and storage requirements within financial services outlined by SEC 17a3-4. Conclusions: 1) Chatter is easy to enable? Yes. 2) Opening a new collaboration channel within financial services raises regulatory compliance questions? UNEQUIVALLY YES.
- Compliance teams are becoming more active in decisions regarding use of Chatter. Again, not surprising, as firms have become accustomed to since FINRA 11-39 in 2011, and as more have acknowledged the futility of blocking social channels including LinkedIn and Twitter. Today, this involvement is moving beyond the yes/no of enabling access toward the issues of social media policy refinement, in determining what specific social media channels can be utilized, which features within those channels are usable by investment professionals whose actions are regulated under FINRA and NASD rules, and how firms intend to monitor, supervise and report on those activities. Simply turning on the capability is the starting point – looking at how you may enable selective access to those users whose activities need to be archived and reported is where many companies appear headed.
- Salesforce Communities creates additional risk. As firms iron out plans to enable Salesforce Communities, it’s important to consider regulatory compliance as part of the discussion. Salesforce Communities enables firms to expose parts of their Salesforce environment to the outside world; creating a collaboration portal for customers, vendors or partners. The Chatter feed is an integral component of Communities and, without Chatter, the benefits of enabling Communities diminish. Similar to “internal” Chatter communications, it’s important to ensure that your archiving solution supports the capture of Chatter content that is authored within Communities as well. Moreover, if your firm creates multiple Communities, your archiving solution should be able to capture Chatter content only from the Communities that you specify, thereby eliminating unnecessary noise from your archive.
- Archiving of social media goes beyond basic storage. For many, envisioned processes for manual collection and basic store/retrieve Chatter content would be - in most cases – woefully inadequate. SEC Rule 17a3-4 in particular contains a number of specific provisions about information storage locations being “WORM-like” and actively managed to ensure information retains its integrity. Simply moving captured Chatter content to a network storage location – or copying to DVDs and sending to giant records warehouses via couriers in small vehicles – may not be meeting the risk profiles of your compliance executives.
- Firms are seeking leverage across other information sources. Enabling the capture and archival of Chatter content is not unique discussion. Firms have already been through this with email. But, firms are reluctant to deploy yet another single-purpose repository to manage that information. In fact, most of the attendees we talked to are seeking to aggregate Chatter with other captured social media content – and leverage their existing processes and technology in place that is used for email. This leverage brings familiarity and comfort to compliance teams – and higher likelihood that SFDC teams can roll-out Chatter faster with fewer compliance obstacles.
Proofpoint, with its Archiver for Chatter solution, can help organizations address these challenges, with a proven track record of capturing and managing content for many leading financial institutions that need to adhere to SEC, FINRA, and other emerging regulatory requirements. For more information about our Social Platform for Archiving solution, please visit http://www.proofpoint.com/social-platform.