Benefit Plan Policies: Social Media

Larry Beebe, CPA

In this series, we are reviewing the written plan policies needed to help your benefit plan stay compliant and operate most effectively. For a full list of the necessary policies and why your plan should implement them, click here.

In the past few years, organizations have been developing social media policies to preserve the rights of employees (and trustees for employee benefit plans) to engage in social networking sites, blogs, bulletin boards and chat rooms, emails and other existing or emerging communications platforms.

A social media policy should contain:

  • An overall policy statement. This statement should contain practical guidance for those employees utilizing social communication channels.
  • Objectives. This section of the social media policy should detail the goals of the social media policy.
  • Disclosure. This section of the policy should disclose what information about the organization can and cannot be disclosed. For example, the policy may detail who in the organization is permitted to respond to media requests. If the organization is mentioned in a personal post, employees may be cautioned to state that the views expressed are personal and do not represent the organization’s views.
  • Respectfulness. This section of the policy may acknowledge the employee’s right to express an opinion while urging the avoidance of language which could be construed to be hateful, harassing, threatening, or intimidating.
  • Other sections of the policy may deal with issues such as:
    • Privacy
    • Security
    • Trade Secrets
    • Legal Matters
  • Penalties. The social media policy normally will detail possible penalties for those who do not follow the policy.

The U.S. National Labor Relations Board has ruled on many cases dealing with social media. Eric Schwartman has developed a social media policy template based on his work in this field. His template can be found at

Share this post