This post may be too late, since brands that intend to engage in "real-time marketing" (RTM) this Sunday have been preparing for months. In some respects, even before the kickoff or the first Super Bowl tweet, the die is already cast--the libraries of tweets, posts and images are all awaiting the right moment to be "spontaneously" broadcast. There's no turning back now, but if there is a shred of chance I might positively impact some brands' plans and help them to avoid a big, messy, public misstep this Sunday, I would like to try to help.

Below are ten tips to help your brand prevent a fumble. I hope you will find all of the tips to be worthwhile, but if I was going to give just one tip, it would be this: Don't do RTM during the Super Bowl. I know, I know--every brand wants to be Oreo (whose "dunk in the dark" post has become the gold standard of RTM) or Arby's (whose Pharrell's hat tweet "won" the Grammys), but the fact is that RTM remains a risky tactic. Brands attempting to hijack consumer conversation about the Super Bowl should not be surprised if their customers resent the advertising-like intrusion.

Even if you "succeed," that impact may be modest at best. It can be easy to get swept up into the excitement of retweets and shares, but those are not true measures of business success. Last year, Samsung was said to hit it big with its Oscar RTM, but despite Publicis CEO Maurice Levy's claim it delivered Samsung a billion dollars of value with a single celebrity selfie, Samsung's smartphone market share slipped 25% from Q3 2013 to Q3 2014.

If your strategy for Super Bowl tweeting and posting is designed to change consumers' perception or purchase intent, go for it, but if all you intend to do is measure RTs and likes, then your strategy may be offsides before the snap. So, if your brand absolutely must tweet and post during the Super Bowl, here are ten tips to help it improve engagement and minimize the risks:

1. Don't insert your brand into every post/tweet during the Super Bowl. Let your intent speak louder than your content.
    
2. During the Super Bowl, don't robo-tweet identical tweets to numerous different people. That's just annoying.
    
3. Don't pathetically ask for retweets. Your brand should earn shares, not beg for them.
    
4. During the event, talk with people. Don't just broadcast to them. Listen--really listen. Don't just make "engaging in their conversation" a euphemism for spam; be real about it.
    
5. I know you want to get noticed and have your brand appear in the Twitter searches consumers will be using during the game, but avoid inserting consumers' hashtags into your branded posts. Don't be Super spammy during the Super Bowl.
    
6. During the event, if you have nothing pertinent to say, shut up. Don't tweet just because you want impressions. Be relevant or be quiet.
    
7. Even though spontaneity matters, have multiple eyes on your Super Bowl tweets. Don't inadvertently embarrass the brand because one community manager fails to realize they are posting something that others may consider offensive or insensitive. Make it a real-time team effort!
    
8. Don't tweet both personally and for your brand during Super Bowl. Focus--if you're working, then dedicate your full attention to the professional task at hand. Moreover, avoid the mistake of tweeting to the wrong account, a mistake that has cost more than a handful of social media marketers their jobs.
    
9. Don't pre-schedule posts. A lot can happen during the Super Bowl, both on and off the field.  Don't get caught posting tone-deaf tweets and posts that do not reflect and align to what is happening at the University of Phoenix Stadium or the world at large in the moment. 
    
10. Your Super Sunday social strategies should be as much about preventing problems as they are about promoting the brand. If you are not as prepared to deal with potential backlash as you are with going viral, then get prepared fast. Don't be stumbling in a critical moment trying to figure out your brand's tone for backpeddling in the event one of your posts or tweets annoys a number of your prospects and customers.

There is, of course, no single way to do Twitter right. People maintain Twitter profiles for a myriad of reasons, and that means it is tough to offer a set of "best practices" to fit everyones' goals. That said, there are a few things that you may be doing that could annoy followers or, worse yet, increase the risk of facing terrible professional ramifications as a result of your tweeting.

Here are three tips to have a more successful and safer time on Twitter in 2014:

• 
  Eliminate auto posting: Several brands (such as Bank of America) got in trouble for automating their Twitter accounts this past year. While your daily Paper.li My-Followers-Are-Brighter-Than-Yours tweets are less egregious, they are nonetheless still annoying and useless--no one is clicking and no one cares. Worse yet, while daily, uninteresting auto-posts may seem harmless, they create clutter that can get you deleted off of lists (and one of the things we should all realize by now is that being included on lists is far more powerful than merely being followed.)
  
  And for the love of all that is holy, if you are auto-tweeting your horoscope, stop! Few care about horoscopes, and even fewer care what your (rather than their) horoscope is each day. If you are auto-tweeting a horoscope on an account tied to your job or employer, you are posting a giant, blinking Twitter billboard that you are self centered, do not know how to use Twitter and should not be followed.


• Detach personal and employer accounts: This is a mistake we have seen time and again: People accidentally posting on their employers' social profile a tweet intended for a personal account. At best, a misdirected tweet is embarrassing to both you and your employer; at worst, it costs people jobs (and loses agencies' accounts).
  
  Chances are you already know that you should not manage your personal and your employers' accounts using the same social management application, but you may have convinced yourself you are smart enough to avoid those mistakes. That attitude is dangerous and wrong--mistakes happen all the time, and you do not want to be the next cautionary case study that earns headlines on Mashable. Use different social apps to maintain your personal accounts and professional accounts; heck, use different browsers, phones and computers to do so, if you can. An ounce of prevention is worth a ton of cure!


• 
  Avoid outlandish humor:  If you want to be the next Sarah Silverman, quit your job, hone your comedic chops, spend years getting heckled on stage and starve while you strive for the impossible dream of becoming one of the very few comedians who can make a living out of it. But, if you care to remain employed, retain your benefits and move up the career ladder, then do not make the same mistake as Justine Sacco (or Pax Dickinson, Taylor Palmisano, Christina Haramboure, Matt Bowman or Miguel Torres).
  
  You should be smart enough to know that the First Amendment does not  protect your job from any idiotic thing you post and that the rules of propriety for a teen or comedian are different than for you, if you are a professional. There are three simple but important questions to ask yourself before posting a potentially offensive humorous tweet:
  
  
  • Would I be say this at the dinner table in front of my parents, spouse and kids?
  • Would I say this in a meeting in front of my boss and peers?
  • Would I say this on stage in front of a large audience?
  
  Remember that a tweet made on a public account is, in fact, a tweet made in front of parents, spouses, children, bosses, peers and a large audience. Do not let your next outrageous, edgy, hilarious tweet make you funniest person applying for unemployment.
    

Twitter is the most powerful broadcast medium ever invented. That makes it a great place to promote, educate, inform, engage, build reputation and network. It also makes Twitter the most dangerous communications tool ever invented. 

Let's start by giving credit where credit is due: Within many companies, there is no more consistently innovative organization than the Marketing Department. Fifteen years ago, while everyone else was deriding the information superhighway as some overhyped playground for nerds, it was the Marketing group in many companies that advocated for the World Wide Web and found the budget to create the first corporate websites. And six years ago, while most executives were chuckling over their kids' obsession with MySpace and Facebook, it was likely the Marketing Department in your company that staked out the firms' social profile on social networks.

But while Marketing Departments may have controlled the first iteration or two of their companies' web sites, that time has now passed. Today, the Marketing Department has responsibility for driving traffic to the site and may control the corporate website's look and feel, but it is very unlikely (if your company is of a certain size) to own the content, the business functionality or the underlying technologies such as web content management, search, hosting, web analytics and the like. In other words, today Marketing brings its traditional strengths and capabilities in reach, scale and acquisition to the web, while other parts of the organization bring their own strengths.

Today, it is common for the Marketing function to own companies' social media accounts. In Spring, SmartBlog on Social Media asked "Who controls the social media efforts at your organization?" and over half the respondents noted their Marketing Department is responsible for social media. No other answer even came close--Public Relations was second with just 18% of the responses.

But in 2014, it is time for change. In the same way Marketing ceded control of corporate websites as the rest of the organization matured digitally, it is now time for Marketing to leave most aspects of social and earned media to others in the organization. That means that primary responsibility for social accounts, daily posting and organic content must shift out of marketing and to other departments, if this has not already occurred.

There are three reasons why this shift is occurring and will continue to do so in 2014:

Reason One: It Is Increasingly Difficult for Earned Media to Furnish the Reach Marketing Needs 

Earned media, that golden promise of the social era, is dying. You don't even need to examine data to know this--just look at the wave of whiny blog posts we have seen this year from marketers accusing Facebook of breaking promises. Apparently, marketers thought Facebook was going to be a place where basic consumer behavior changed: As more brands joined social media and increased their content marketing output, consumers who avoid ads in every other medium would suddenly welcome and engage with marketing content on Facebook.

Of course, that isn't what happened--people sign into Facebook and other social networks to see what friends, family and peers are up to, not to get marketing content. On Facebook, as more brands paid for access to users' news feeds, it was absolutely inevitable that brands would find it increasingly difficult to "earn" their way into fans' news feeds organically. (And if you think I am demonstrating 20/20 hindsight, feel free to read my blog post from almost two years ago, "Did Facebook Just Kill Earned Media?")

Ignite studied 689 posts across 21 brands; only one brand saw an increase in organic reach.

How difficult is it becoming to generate earned media on Facebook? Two recent studies demonstrate that engagement and penetration are sinking very quickly. Komfo found a 42% decrease in fan penetration from August to November, and an Ignite study revealed that in the week following Facebook's December 2nd news feed tweak, brand page organic reach declined by 44% on average. Ignite notes, "Facebook once said that brand posts reach approximately 16% of their fans. That number is no longer achievable for many brands, and our analysis shows that roughly 2.5% is now more likely for standard posts on large pages."

And if you think the earned media bloodletting is over, think again. The slow decline of earned media on Facebook will continue in 2014. Ad Age recently reported that Facebook is telling marketers, "We expect organic distribution of an individual page's posts to gradually decline over time as we continually work to make sure people have a meaningful experience on the site."

Make no mistake, the phenomenon of shrinking earned media is not just a Facebook issue. Facebook is on the cutting edge of social media because of its scale and longevity (not to mention investor expectations, with a market cap almost 50% greater than Twitter's, LinkedIn's and Yahoo's combined), so it provides a peek into the future of all social media. As more brands pay for access and as social networks strive to monetize, brands' earned media will get pushed aside.

Earned media is dead; long live paid media! Marketers should not mourn the loss of earned media but rejoice that their traditional skills and abilities are in ever higher demand. The need for paid media expertise in social media has never been higher and is going to continue growing. The Marketing Department is uniquely equipped to stay abreast of Facebook, Twitter and other social networks' rapidly evolving ad programs, develop and test targets and creative, and measure advertising success. Marketing can focus on what it does best and leave the rest of social media to others.

Exception to the rule: While it is ever more difficult to gain access to consumers via earned media, this is not a universal problem for all categories. Entertainment, news and style brands continue to have opportunities to increase reach and engagement both in traditional social networks such as Facebook and Twitter, as well as the newer breed of visual platforms such as Vine, Instagram, Pinterest and perhaps, if they can prove themselves to marketers, Snapchat and Whatsapp. Most other categories simply do not have the luxury of innate consumer interest, and trying to manufacture it where little exists only pushes brands to, well, let's move on to reason number two...

Reason Two: The Harder Marketers Try To Win Earned Media, the Greater the Risks

You're getting a little choked up with the emotion of this respectful post, aren't you?

As earning organic social media becomes more difficult, marketers get more desperate to break through, which elevates the risk for brands. No consumer hopes for a daily dialog with their brand of canned pasta, as evidenced by the fact Spaghettios has just 2,600 people "talking about the brand" despite having amassed 518,000 "fans." Since no national brand can succeed with a marketing effort that has a reach of just 2,600 consumers (and since some Social Media Marketing Manager's job depends on it), Spaghettios' Marketing Department has to churn out daily content that struggles to get more attention than other brands. The more they produce and the harder they try, the greater the risks, so it is of little surprise that Spaghettios stumbled instead of soared. The brand's recent Pearl Harbor Day post of a smiling brand logo waving the American flag was widely criticized and embarrassed the brand.

Spaghettios apologized and said its intent was to pay respect, but you and I both know that is not true. This was marketing content, and the goal in posting it was to achieve what marketers always want to achieve in social media--likes, comments and shares. The intent of the smiling cartoon Spaghettio was not to pay respect but to create brand engagement (and in that, at least, the brand succeeded).

Of course, I should not pick on the Campbell Soup brand when there is an almost limitless number of examples of social marketing missteps to choose from in 2013: The #AskJPM, #AskBG and #AskRKelly hashtag dustups; endless look-alike newsjacking after the royal baby's birth; embarrassing campaigns to extort retweets in exchange for charitable dollars; failure to control social accounts from dismissed employees; pathetic fake account hacks to jack up follower counts; branded hashtags inserted into tweets about tragedies; accidentally racist posts; misguided humor about fatal airport crashes. Was that enough, or should I go on?

Cole defended his tweet as a way to "provoke a dialogue." How far is your brand willing to push to get attention?

Okay, I will! Epicurious insensitively exploiting the Boston Marathon tragedy for social content. Kenneth Cole joking about war to sell footwear. Taco Bell turning fans into detractors by mistakenly sending thousands to restaurants that were not yet carrying a promised new product. Nokia failing to put a language filter in place, permitting someone to post "F### you" on its corporate account. (Yes, that "F" word!) The Onion calling a nine-year-old girl a c###. (Yes, that "C" word!)

In 2014, we will see still more brand blunders in social media, but there is a simple solution: Stop trying so hard! With shrinking opportunities to reach the kind of mass scale marketers want and need, consider the risks versus the potential modest rewards. If you do, many of you will shut off the lights on those special-event real-time marketing newsrooms--your brand is more likely to be criticized for spamming consumers' conversations than be next year's Oreo Blackout. Put an end to those tweet-this-or-we-won't-save-a-starving-child campaigns, which consumers increasingly see as mercenary attempts to boost brand reach. Stop desperately asking people to "like this if you love Fridays." Tactics like those may deliver some bumps in your social media analytics, but they are more likely to create negative sentiment than to boost consideration, purchase intent or loyalty at any reasonable scale.

Note that I said to stop trying so hard, not stop trying altogether. Brands certainly have a place in social media, but the time has come to focus not on what your marketing department wants but on what your customers want: Deals, information, education, customer service, co-creation and social functionality. In this list, the Marketing Department is best aligned to furnish just one type of content--promotions. The remainder of the content and services are better left to Public Relations, Customer Care, Product Management and Development and Channel Management.

The Marketing Department is an important provider of content for social channels, but that does not mean those social channels should be run by Marketing with the goal of producing marketing results. In the coming year, I anticipate we will see more Public Relations and Customer Care departments take over companies' social accounts. This will decrease the chances for the kind of social missteps that embarrass brands. No PR or customer service department will ever post an image of a smiling Spaghettio waving a flag, newsjack a national event or fake an account hack. Those departments do not need to win a battle for hundreds of thousands of eyeballs in order to succeed, and they will not push the envelope until, inevitably, the envelope tears and creates a social PR mess.
Exception to the rule: If your brand does not offer the kind of customer experience that earns advocates, then attempting to earn organic attention at scale is difficult and risky. If, however, your company creates advocates with a great product or service experience, that bestows opportunities for social media marketing that is safer and more prone to success. Coca-Cola, USAA, Apple, Trader Joe's and other successful brands don't succeed in the real world because they have great social media; they succeed in social media because they offer a great experience in the real world.

Reason Three: There is Little Evidence that Social Media Marketing Success Drives Business Success

No matter what your corporate social media scorecard may imply, all engagement is not created equal. Getting consumers to engage with your jokey posts or videos is not the same as making a brand impression, building purchase intent or driving sales. Too many brands continue to chase social media metrics while failing to measure how and if social media efforts drive business results. For every Dove "Real Beauty" or Secret "Let Her Jump" that delivers measurable marketing results, there are dozens of other social campaigns that fall far short.

It is easy to see the gap between social media success and business success by looking at Kmart's 2013 efforts. Few brands were as talkable as Kmart this year. Thousands of blog posts and tweets trumpeted the brands' success with funny viral videos like "Ship My Pants" (20 million views!), "Big Gas Savings" (6 million views!), "Show Your Joe" (16 million views!) and the new "Ship My Trowsers" (3 million views in a week!) Even though Kmart, which is owned by Sears, amassed twice as many views as top-rated primetime program NCIS has viewers, the retailer has continued its slow decline, with same-store sales falling 2.1% in the second quarter and an equal amount in the third quarter. As Mashable's Todd Wasserman notes, "It's hard to make a case that the ads did much for owner Sears's bottom line."

In the article on Mashable, Sears chief digital marketing officer says he judges success by "the amount of engagements in social media surrounding the brand." It is long past time for digital and social media leaders to stop this kind of idiotic babble. Marketing that entertains or engages without driving measurable brand or business benefits is failed marketing. Television ad buyers don't claim success based on gross rating points, and neither should digital and social marketers claim success can be counted in "likes" rather than dollars, new customers or brand equity (such as awareness and purchase intent).

Kmart is not the only brand we can study to see the tenuous relationship between social media success and business success. Late last year, Red Bull launched an amazing social campaign around Felix Baumgartner's record-setting skydive. The YouTube video earned 35 million views and got everyone talking. Two months ago, uberVU evaluated Red Bull's and Monster's social media presence and declared Red Bull the winner. But while Red Bull may be winning the social media battle, it is losing the market share war. In recent years, Red Bull has been slowly bleeding market share to Monster, and the trend continued in 2013. In Monster's third quarter earnings call, CEO Rodney Sacks announced that Monster's year-over-year growth was greater than Red Bull's and that Monster was close to overtaking Red Bull in US market share.

Two of the biggest social media marketing successes of the past fourteen months seem to be driving no demonstrable brand success. Maybe my Kmart and Red Bull examples seem unfair since, of course, social media is but one small factor in overall brand success or failure. After all, customers disappointed with past Kmart experiences won't be enticed into stores with a funny video, and Red Bull may be leaking market share because competitors have better product innovation. If you buy this line of reasoning, then you are acknowledging my point--entertaining consumers with funny videos and knee-slapping posts do little to impact the bottom line when consumer perception of the brand is shaped by more powerful experiences with the product or service.

I see little evidence that entertaining consumers with social content imparts benefits to brands. Consumers are awash in entertainment options, and your brand cannot compete with the likes of Beyonce, PewDiePie, Cinema Sins, Rihanna or Reddit. Those channels and pages, and thousands of entertainment options like them, are unencumbered by the limitations faced by your brand, such as reputation considerations, brand fit, legal and regulatory concerns and, most of all, the need to drive purchase of goods and services. (Yes, Rihanna and Beyonce want you to buy their music, but in that case their entertainment is their product, while your brand is left producing diverting videos in the wild hope they will drive folks to purchase pistachios or bottled water.)
There remain several ways marketers can succeed in social media, including paid media and using social networks to distribute promotions. In addition, brands that create advocates through superior customer experience can work to increase Word of Mouth. For many marketers, however, 2014 will be the year they must contend with the diminishing reach, increased risk and dubious business results of organic content and earned media. The earned media equation is changing, and marketers must ensure they don't make the mistake of committing to a strategy that cannot deliver the audience, opportunities and results necessary.

The time is right for a reassessment of your brands' cost-benefit equation with respect to marketing content in social media. If you are achieving significant organic scale and positive outcomes for a reasonable cost, keep up the good work. But if you are employing writers, videographers, photographers, illustrators and other creatives to develop social media content that is reaching too few customers and fails to deliver measureable results, then a change is in order.

There is no shame in acknowledging that earned media does not offer the marketing opportunities that we hoped for years ago as social media was developing. There is, however, shame in continuing to invest if the strategy is not producing results or in striving so hard for marketing success that the company is embarrassed with a social media misfire.

In 2014, I believe the time has come for a normalization of roles in social media. Your organization has professionals with decades of experience creating earned media, and they are not in Marketing but PR. Your organization also has professionals able to scale one-to-one relationships, answer customer questions and engage consumers individually, and they are found in Customer Care. These are the departments that can better manage corporate social accounts. More importantly, they can measure success on their own terms, with metrics based on responsiveness, reputation and satisfaction rather than on acquisition and sales.

The shift has already happened at many companies, but if the Marketing Department at your firm still "owns" the corporate social media accounts, it may be time for them to hand over the keys. Moreover, if your marketing function is ramping up a content marketing program at the same time earned media opportunities are vanishing, caution and careful consideration of costs and goals is advised. Marketing will always have a role on social networks, but the time has come to recognize that social media is not primarily a marketing channel but is better aligned to the longstanding responsibilities and capabilities of others throughout the organization.

Financial service firms are a conservative lot, filled with risk, compliance and legal professionals who are ever vigilant detecting, preventing and mitigating risk. Generally, that is a good thing, since no one wins when your bank, insurance company or investment firm takes unnecessary risks.

Actual photo of FinServ executive considering social media regulation.

But at times, in periods when technology, consumer behavior and customer expectations are rapidly evolving and regulation seems less certain, this natural conservatism can get in the way of good decisions. When this happens, opportunities to enhance and protect the interests of both the business and customers can be lost.

Now is one of those periods, but change is imminent. Even Federal regulators, in their own subtle and maddeningly vague manner, are telling FinServ firms it is time to stop fearing and start embracing social media. Two recent publications from the FFIEC and SEC demonstrate regulators are looking for financial institutions to be more assertive in realizing social media benefits and independently managing social media risk.

Waiting for perfect guidance from regulators is never the road to success, since perfect guidance is never furnished; consultants and law firms make rich livings in the gap between regulatory guidance and certainty. Moreover, as financial institutions wait for better guidance from regulators, it can leave the industry in general and certain companies in particular lagging far behind more innovative competition, not to mention the level of service and responsiveness consumers have come to expect. With a careful reading of the two new reports from Federal regulators, it seems they, too, are concerned that an overly cautious approach is harming the industry.

Social Media Risks: Present but Manageable

Social media poses new risks for FinServ firms, and there are good reasons for firms to proceed with caution; however, there are no good reasons for the level of anxiety and sluggishness seen at many firms. Many Financial service companies can proceed with a great deal more alacrity for several reasons:

• Substantial guidance has already been furnished by regulators, including FINRA (Financial Industry Regulatory Authority), SEC (Securities and Exchange Commission) and the FFIEC (Federal Financial Institutions Examination Council). At the state level there is a patchwork of regulators across 50 states, but thus far organizations such as the NAIC (National Association of Insurance Commissioners) and state regulators have taken a very similar tact to Federal regulators; the association's December 2011 social media white paper for state regulators was not terribly different than the guidance coming at the Federal level. While there are gray areas (such as whether a LinkedIn recommendation is really a forbidden testimonial), many actions by firms and licensed professionals are clearly within the safe zone, provided reasonable precautions are taken. For more information, check out the excellent guide to FINRA regulations in social media from Actiance.
   
• No firm or person has yet been been cited by a regulator for actions in social media, unless those same actions would have been cited in any other medium. Regulators' enforcement has been sane, reasonable and understandable. Do not do anything in social media that you should not do in email, print, in person or on the web, and you will find it difficult to run afoul of the regulators.
    
• For years, tools such as Hearsay, Socialware and Actiance have been available to help firms mitigate and manage social media risk. These platforms are not complete solutions--firms still need to take additional actions such as educating financial professionals, monitoring social media for violations and archiving to the requirements set by Rule 17a-4--but existing social media management platforms help mitigate much of the risk.
    
• The risks to firms from actions of registered representatives (RRs) can be limited with reasonable precautions. An excellent post on the Hearsay Social blog cites an instance when the Department of Justice declined to take action against a firm because it had adequate measures in place that were circumvented by an RR in the course of violating the rules. That case did not involve a social media issue, but Hearsay states, "as long as firms have a clear and concise social media policy with a governance structure that identifies roles and responsibilities and incorporates controls for the use and monitoring of social media, an employee training program, and appropriate oversight and monitoring of social media use, they should not have liability for an individual RR’s violation." 

In 2013, there are new signs regulators are not just open to but are actively encouraging financial institutions to adopt a more assertive stance in social media with respect to both exploiting benefits and managing risks. In two recent publications, the FFIEC and SEC tell the industry it cannot ignore social media and must apply good judgment to its social media interactions and processes. Of course, neither government body says that in such clear language, but you do not need to dig too deeply to see that financial regulators do not want to overburden FinServ companies (or themselves) with needless and detrimental social media regulation.

Social Business Referenced in FFIEC Proposed Social Media Guidelines 

In January, the FFIEC issued proposed guidelines on social media. The FFIEC is an interagency body that encompasses the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Consumer Financial Protection Bureau (CFPB). Also of note is that the FFIEC, upon finalizing this guidance, will urge state regulators to adopt the same rules.

It is not difficult to sense that the FFIEC sees social media changing not just marketing and communications but financial products and services. The document addresses and references the advanced use of social media and social business by FinServ firms several times:

• "Financial institutions may use social media in a variety of ways, including marketing, providing incentives, facilitating applications for new accounts, inviting feedback from the public, and engaging with existing and potential customers, for example, by receiving and responding to complaints, or providing loan pricing." Note the inclusion of forward-thinking social strategies, such as providing incentives and facilitating applications within social media; this gives a hint at how the FFIEC views social impacting business, not just being used for service and communications.
   
• Some firms may choose to "use(s) social media to engage in lending, deposit services, or payment activities" and "Social media may be used to market products and originate new accounts."
   
• Social media can be used to "to facilitate a consumer’s use of payment systems" and "under existing law, no additional disclosure requirements apply simply because social media is involved."
    
• Not only are financial firms not discouraged from prospecting in social media, the FFIEC provides reasonable guidance for doing so, stating that "a financial institution that relies heavily on social media to attract and acquire new customers should have a more detailed program than one using social media only to a very limited extent."
    
• Generally, regulators concern themselves with risks and regulation rather than promoting the advantages of new technologies, but the FFIEC makes a point of addressing that social media "has the potential to improve market efficiency" and can "help users and providers find each other and match products and services to users’ needs."
      

At a time when many FinServ firms are afraid even to mention products in social networks, federal agencies are suggesting financial institutions might use social media for applications, lending, deposits, payments and matching products to customer needs. This should be a huge wake up call to FinServ executives.

The document observes there are risks in social media, but it takes pain to pin those risks not to actions in social media but the potential failure of firms to monitor and manage those actions. The FFIEC expects people to make mistakes and, at times, use poor judgment, but the responsibility falls to firms to protect themselves and their registered representatives: "Increased risk can arise from a variety of directions, including poor due diligence, oversight, or control on the part of the financial institution."

The FFIEC also tells FinServ firms that there is no way for them to avoid addressing social media, regardless of what they opt to do in the channel. "A financial institution that has chosen not to use social media should still be prepared to address the potential for negative comments or complaints that may arise within the many social media platforms... and provide guidance for employee use of social media." The report also notes that inaction on the part of some firms is increasing risks because institutions' "policies and procedures governing certain products or activities may not have kept pace with changes in the marketplace."

When a group of federal agencies begins to outline new business opportunities furnished by digital and social technologies and suggests companies are accepting risk by failing to keep up with the changes in our world, you do not need to read between the lines to get the message. The FFIEC is not suggesting recklessness, but it is clear they do not want firms failing to exploit new opportunities out of fear of regulation.

Greater FinServ Independence and Judgement Advised in SEC Social Media Guidance Update

In a new "Guidance Update" published by the SEC last Friday, the agency cries "Uncle" with the flood of social media content that firms are filing with FINRA. It cites "an abundance of caution" that is causing "many mutual funds and other investment companies (to) file materials on their social media sites with FINRA unnecessarily." (That's regulator-speak for "Stop being a bunch of wusses!")

The report is an acknowledgment that the SEC must furnish more specific guidance, but it also is evident the SEC believes firms must begin to apply better judgment in social media and be more assertive in managing risks rather than deferring them to regulators. The SEC's Update gives a level of specificity far beyond anything furnished by other regulators to date, even going so far as to provide actual tweets and posts that "would not trigger a filing requirement." The guidance suggests that the following social media posts are safe and do need to be filed with the agency:

• An incidental mention of an investment company or family of funds that is not related to a discussion of the investment merits. What is notable is that you can market your financial products in social media, provided you do not mention the investment merits. For example, the SEC suggests this is an acceptable tweet that need not be filed:  “Consumer Reports has written an article in which it mentions our Brand X Rewards Card. Are you a card member?"
   
• The incidental use of the word “performance” in connection with a discussion of an investment company or family of funds, without specific mention of a fund’s return. The word "performance" is not forbidden in social media, provided you do not promote a fund's return. For example, "Click on this link (website url) where we provide full details of our yearly performance since inception.”
   
• A statement unrelated to a discussion of the investment merits of a fund that includes a hyperlink to general financial and investment information or commentaries on economic, political or market conditions. The SEC notes you can tweet things like "Here’s a Q&A with our Portfolio Manager, John Doe, regarding his views on the economy for 2013. (website url)"  or "Gold and silver have provided a relatively low correlation to stocks and bonds over the last few years. (website url)."
   
• A response to an inquiry by a social media user that provides factual information not related to a discussion of the investment merits of the fund. Firms need not fear direct and detailed responses in their social media replies, provided they do not discuss investment performance. For example, if a consumer asks, "What was the NAV for ABC fund on Friday?," the SEC says firms may reply "$xx.xx." Another example furnished by the SEC notes that you can address the reasons investments are included within a fund; for instance, if a consumer posts "Why are your funds such a large investor in ABC Manufacturer’s stock?" it is acceptable to respond, "As you know, ABC Manufacturer is found in many broad-market indices that our index funds are obligated to track so some of our index funds hold those shares as a result."

Did you detect the recurring theme in that guidance?  "Not related to a discussion of the investment merits or return" is repeated in one form or another time and again. The SEC is clear in telling financial service firms they can talk about their products, provide links to their products and share general market commentary without needing to file this content with FINRA--just don't tweet returns and investment merits. Firms have been proceeding too cautiously and over-filing, which means the are not using social media to the extent the SEC believes is possible and good for the industry.

Despite numerous examples of employees losing their jobs due to dubious social media activities, many continue to harbor misconceptions about free speech and employment law in the U.S. Simply put, your employer is under no legal obligation to respect your freedom of speech. Failing to recognize this can cost you your job and hurt your career as it has for people ranging from celebrities and pro athletes to job candidates and interns.

The First Amendment of the U.S. Constitution secures your right to free speech, but only from Congress. The amendment establishes limits as to the laws Congress may pass that abridge your freedom of speech, but it offers no protection should your employer send you packing over a post or tweet. A variety of state laws and National Labor Relations rules may offer some protection under certain circumstances, but an ounce of prevention is worth a metric ton of cure when it comes to your job and career.

The attitudes of younger professionals are particularly dangerous. While many older folks have a tendency to approach their social media activities with a bit of caution, today's young adults just entering the workforce have grown up with the transparency of the social era. They tend to think everything and anything is in bounds when it comes to "personal" social profiles. They are wrong, and there is a trail of lost jobs and broken careers to prove it.

Here are seven ways people have found to lose their jobs because of their activities in social media:

1. Post Insensitive Ethnic and Racial Comments: Just yesterday, Voula Papachristou, a Greek Olympic athlete set to compete in London, was bounced from the team. Her offense was a single tweet; a bad, racially insensitive joke: "With so many Africans in Greece, at least the West Nile mosquitos will be eating food from their own home." This 23-year-old woman has spent her entire life training for an opportunity she will likely have only once in her lifetime, and she trashed it in the time it took to broadcast a stupid 140-character tweet. It is likely 2012 was Papachristou's only Olympic opportunity--in 2008 she competed in the World Junior Championships and in 2016 she may very well be too old to make the team--and now she will be watching the 2012 Olympics on television rather than representing her country. The head of the Hellenic Olympic Committee said something every employee should heed: "She made a mistake and in life we pay for our mistakes."
      
2. Post Party Pix: We all love to share photos of good times, but you should consider potential ramifications before uploading that photo of you doing a beer bong. In 2009, teacher Ashley Payne resigned after an anonymous email claimed that a student had seen her vacation shots, including ten pictures of her drinking alcohol, and that this set a bad example. In 2008, 18-year-old New England Patriots cheerleader Caitlin Davis was fired after some offensive party photos appeared on social sites. Combining the first and second bullet points in this list, Davis was seen leaning over a passed-out friend whose body had been covered with graffiti that included swastikas and comments such as "I'm a Jew."
      
3. Use Social Media After Calling In Sick: If you call in sick, just remember that your boss and coworkers use Facebook and Twitter, too.  In 2009, a Swiss insurance worker lost her job after surfing Facebook while off sick. She told her boss that she needed to miss work because she was unable to work in front of a computer but was then seen posting on Facebook. (She claimed it was on her iPhone from bed, but her employer was not buying it.) In 2007, intern Kevin Colvin told his boss that he needed to miss work due to a family emergency, and then he posted a photo of himself partying in a Tinkerbell outfit. If there is anything worse than getting fired because your employer catches you in a lie, it might be doing so while having your embarrassing photo shared worldwide.
      
4. Post Evidence Of Rule Violations: Breaking your employer's rules is dumb; doing so and then sharing the evidence on a social network is insanely stupid. Just last week, three employees at a Mayfield Heights, Ohio Burger King lost their jobs because one thought it would be funny to post a photo standing in tubs of lettuce. The picture was uploaded to 4chan, an online community, and 15 minutes later community members had tracked down the restaurant location using the GPS data encoded in the file. This is hardly the first time Burger King has faced this sort of problem--in 2008, several employees of another Ohio Burger King lost their jobs after a video appeared online of an employee taking a bath in the restaurant's kitchen sink. And in 2009, two Domino's employees not only were canned but also arrested after posting a YouTube video of themselves despoiling customers' food. (Imagine the luck they will have landing jobs in the future, since they not only have to admit they were fired but also reveal they have police records). Even well intended posts can get you terminated if they violate employer policies. Earlier this year a restaurant dismissed an employee after he posted an image of a receipt revealing a particularly bountiful tip from quarterback Peyton Manning. The server obviously intended this as a positive shout-out to Manning's generosity, but as the restaurant owner noted, "This goes against every policy we have."
       
5. Dump on Your Employer in Social Media: The people who pay our paychecks tend to get a tad grumpy when we return the favor by bad-mouthing them publicly. Biting the hand that feeds you is never a good idea. Just ask Connor Riley, who found a way to lose a job before she even started. Upon receiving an offer, the 22 year old tweeted, "Cisco just offered me a job! Now I have to weigh the utility of a fatty paycheck against the daily commute to San Jose and hating the work." Cisco promptly rescinded the job offer to save her the effort of making that difficult decision. And, proving you are never too big or too famous to be canned for shaming your employer, Kansas City Chiefs running back Larry Johnson lost his job after attacking his coach and fans in a vulgar tirade on Twitter. Fans petitioned for his release, and the team complied. In another NFL incident, Dan Leone, an employee of the Philadelphia Eagles stadium, lost his job after criticizing the team on Facebook for losing safety Brian Dawkins to the Denver Broncos. He called the team "retarted" and his employer called him "unemployed." (Leone did, however, receive two tickets to the Broncos/Eagles game, courtesy of Dawkins.)
     
6. Embarrass Your Employer in Social Media: We all know that in the age of social media, an organization's reputation is one of its most vital assets. No surprise, then, that companies seek to protect those assets from employee lapses. An Arizona Daily Star reporter tweeted a criticism of a headline in his newspaper and was asked to refrain from social media activities that could damage the paper's reputation. Later, after a local TV station complained when the reporter mocked the spelling in one of its tweets, the reporter was dismissed. He appealed, but the National Labor Relations Board upheld his termination. Those of us who are responsible for corporate social media are in an especially risky position when it comes to protecting (or harming) our employers' brands. Last year, an employee not only lost his job but got his agency fired when he mixed up his personal and corporate Twitter accounts, resulting in Chrysler tweeting, "I find it ironic that Detroit is known as the #motorcity and yet no one here knows how to (expletive) drive." And, in yet another example that demonstrates even celebrities are not immune to these dangers, comedian Gilbert Gottfried lost his gig as the voice of the Aflac duck when he posted truly insensitive tweets following Japan's tragic tsunami. One such tweet read, "I just split up with my girlfriend, but like the Japanese say, 'They'll be another one floating by any minute now.'" A bad joke is not when no one laughs--it's when you lose your paycheck.
     
7. Insult Your Employer's Customers: Everyone can get frustrated with customers every now and then, and we all know the customer is not always right, no matter how the old saying goes. It is the way you choose to deal with those natural frustrations that can mean the difference between your job and unemployment. Two years ago, 22-year-old server Ashley Johnson stayed late to wait on a table and then felt slighted by the small tip. She took to Facebook with a vulgar post calling the customers cheap and mentioned the restaurant by name, resulting in her dismissal. People took to the restaurant's Facebook page to protest the action, but the company stood tall (and did the right thing), noting "As an employer, it is necessary to enforce policies for the benefit of all our hardworking employees and valued customers... We welcome your comments, but please keep it clean!" In 2008, Virgin Atlantic fired 13 cabin crew members after they posted messages on Facebook referring to passengers as "chavs," an insult used in the U.K. And back in Facebook's infancy, seven employees of a Canadian grocery store chain lost their jobs for deriding customers in a Facebook group. One employee said, "instead of talking in a locker room, we are talking on this." (Note: Unless your locker room is broadcast to the world and contains a search function, it is safer than Facebook.)

I am not suggesting you avoid social media out of fear for your job security, but it should not be news that posting and tweeting come with risks. What can you do to diminish these risks?

• Be aware of the risks.
• Do not post anything you would not say to your boss (or your mom).
• Never, ever criticize or make "funny" observations about your boss, your employer or your coworkers.
• Know your employer's policies about communication, social media and protecting customer data.
• Filter yourself--if you have a moment's doubt, don't post it!
• Protect your friends--if they are doing something stupid on a social network, tell them quickly.
• And if you fear you are unable to filter yourself sufficiently to protect your job, build a social media firewall between you and your employer:
• Lock up your account and make it private
• Remove your employer from your Facebook and Twitter profiles
• Separate your LinkedIn account from your other social media profiles
• Do not post frequent check-ins at your employer's location
• Do not friend and follow your boss and coworkers

These are not blanket recommendations, because my social media experience has been very positive, resulting in strong working relationships and an enhanced career. But if you fear, in a moment of weakness, you will let a sarcastic post fly or post an embarrassing picture after one too many, then take action now. We live in a world where your missteps can haunt you forever (Thanks Google!), and there is no "fixing it" after the damage is already done to your career.

I was reading about the latest so-called "social media disaster"--this one from Qantas Airlines--when I was struck by a sentence in the Reuters article: "PR experts said the campaign was... a classic example of the dangers of unpredictable social media." I don't mean to be hard on Qantas--any company or human can inadvertently make mistakes--but this situation was about as unpredictable as the sun rising or Groupon's stock falling.

Qantas' social media campaign was intended to get travelers using the hashtag #QantasLuxury and describing their "dream luxury inflight experience." The timing was, at best, dubious, coming just a day after Qantas and its unions broke off contract negotiations and one month after Qantas stranded 70,000 travelers by grounding its fleet due to union woes. Furthermore, the prizes in this promotion weren't, as you might expect, trips to exotic locales but pajamas and toiletry kits. The effect was to spur many negative, sarcastic and angry responses about Qantas in social media channels.

So, are you shocked at the outcome? Do you find the social media backlash "unpredictable?"

How many instances of social media PR disasters are truly unpredictable? There are cases when a brand can be caught by surprise--such as when activists launch a critical social media campaign or a single consumers' complaint becomes a meme--but are most social media issues really fluky and unforeseeable? This isn't an inconsequential question; if social media is a flaky and erratic channel, then it is an inhospitable medium for business.

I believe social media is not a game of chance but more akin to the weather. Weather forecasters may frequently get tomorrow's forecast wrong, but that doesn't mean we consider sun, rain, snow or lightning unpredictable.

This year, lightning strikes will ignite around 24,600 fires to which US fire departments will respond. One lightning strike is unpredictable;  tens of thousands of them across the country is not. Because we know this, we prepare. We purchase insurance, install lightning rods, use surge protectors and tune into the National Weather Service to stay informed when weather turns severe.

Any brand can be struck by social media lightning at any time, so the smart ones prepare--they engage advocates, provide excellent products and services, amass fans and followers, deploy social business strategies, use listening platforms and employ community managers to respond with speed, empathy and care for the customer. These are the components that ensure if and when a brand is struck by social media lightning, brand damage is limited.

But while any brand can be struck, we also have to recognize there are actions our organizations may do that can make it a target.  Golfers know better than to stand in the middle of a fairway holding a metal club above their head in a thunderstorm, yet brands seem to do the social media equivalent quite frequently.

Many of the social media PR disasters that have occurred weren't unpredictable. Brands may not be able forecast the specific social media reaction, but we know risk increases when brands raise prices or fees, redesign products or logos without engaging loyal customers, fail to hear concerns about environmental policies, ignore consumer complaints, engage in dubious business practices, or--as in Qantas' case--deploy marketing or take other actions that fail to understand the brand's current relationship with consumers.

Social media is not unpredictable. I can predict that your organization, if it is any size at all, it will be struck with social media lightning this week. Your brand will receive critical posts on its Facebook wall, earn one-star ratings on review sites and get a handful of gripes on complaint sites like PissedConsumer.com.

There is no insurance for social media lightning--no one will compensate your brand should a misstep cause lost business or brand damage--but smart organizations can prepare and protect. They do so by understanding the social media climate, conducting business in ways consumers expect, setting their business and communication strategies appropriately and investing in social media to protect their brand from the inevitable.

Consumer storm clouds are brewing. There is a 60% chance of consumer complaints, some industries will face a hard sentiment freeze and companies may experience localized areas of brand flooding. Whether social media will be shelter from the storm or the storm itself has more to do with your enterprise than the "unpredictable" nature of social media.

There is an awful lot one can learn from the remarkable Steve Jobs, of course, but one thing stands out to me--one single thing that can get lost among the many lessons his story offers: Failure.

The people who change the world are not brighter than everyone else is; there are many bright people with great ideas. It isn't that Steve had vision; when I worked in the Bay Area, I found I couldn't take a dozen steps without running into someone with an exciting vision for the future. And it isn't that Steve better focused on the needs of humans; that is certainly an integral part of his success, but every organization is full of people capable of putting customers first.

No, the one thing that sets Steve Jobs apart from others is not success but failure. Reading his biographies and tributes this week reminded me of another hero of mine, Walt Disney. Their tales are remarkably similar in many ways.

We Americans have a terrible habit of distilling the stories of our great men and women into simplified and boring soundbites of success--Walt Disney invented Mickey Mouse! Steve Jobs invented the iPad!--while ignoring the long, crooked, difficult, brave roads they took to realize that success. We like to believe that success is what defines the American spirit, but the truth is the opposite: Failure is what defines the people who achieve greatness.

Steve Jobs and Walt Disney are American success stories--and they both failed in spectacular fashion. Steve Jobs produced the Apple III, a computer with so many hardware issues that one of the solutions (I'm not kidding) was to drop the computer two inches to reseat the chips on the motherboard. Walt Disney's first animation effort went bankrupt and he lost the rights to his first commercially successful character (the forgotten Oswald the Lucky Rabbit.)

For most, the story would have ended there. Steve Jobs, pushed out of the very company he founded, could have spent his life developing products that didn't push the envelope but delivered his family a very comfortable standard of living. Walt Disney could have given up animation--something he'd briefly attempted in the past--and sought work in the booming Hollywood movie business. But neither did--they learned from failure and eagerly dove back into the deep end of the risk pool. Said Steve Jobs, "It turned out that getting fired from Apple was the best thing that could have ever happened to me... Sometimes life hits you in the head with a brick. Don’t lose faith.”

What is remarkable about both Steve Jobs and Walt Disney isn't merely that they persevered after failure; instead, the defining characteristic of these great men--the one thing we can and should learn from Jobs and Disney--is that they never stopped embracing risk even after they achieved success. It is difficult enough to make risky decisions after one is prosperous and comfortable, but imagine making those same risky decisions after having suffered the kind of confidence-shaking flameouts that Jobs and Disney experienced.

Disney achieved great success and recognition with Mickey Mouse, Donald Duck and The Three Pigs, yet he risked it all to push his company into the dangerous and untested waters of full-length animated movies. He was forced to release "Snow White" sooner than he wanted when the banks funding what had come to be known as  "Disney's Folly" refused to advance any more credit. Snow White earned Walt money and recognition, yet he risked it again and again on pet animation projects, live-action films and the riskiest bet of all--theme parks. Having tasted the bitter pill of failure, he nonetheless risked his reputation and wealth frequently.

Steve Jobs did the same. After being dumped from the company he founded, Jobs turned his attention to new risky endeavors. He launched a new software company called NeXT, Inc. and invested $50 million of his own money into Pixar. NeXT floundered, Pixar soared and Jobs was soon back at the helm at Apple. For most of us, the satisfaction and recognition of a triumphant return to the company that dumped us would be validation enough, yet Jobs took a salary of $1 a year and repeatedly placed risky bets on new business models and innovative technology. Jobs might have stopped at any point in his journey and retired with the kind of wealth and accolades most can only dream of, yet his risks and hits kept coming--iMac, Macbook Air, iPod, iTunes, iPhone and the iPad.

Most within corporate America work their entire careers avoiding risk. Some do it blatantly, taking pride in saying "no" to anything new that comes along, protecting the bottom line and corporate reputation from anything that feels a little dicey. Others avoid risk superstitiously, hiding behind focus groups, best practices and spreadsheets that promise (but rarely deliver) ROI.

In Human Resource departments, for example, the risk avoiders hire only candidates who present excellent education records; Steve Jobs dropped out of college and Walt Disney left high school after one year. In Marketing Departments, the risk avoiders spend big money on TV and print while moving cautiously into digital and social; Disney made huge bets before others on Technicolor in movies and on the nascent television medium, and Steve Jobs doubled down on mobile computing at a time when few expressed a desire for expensive mobile devices.

Avoiding risks doesn't get someone fired. No one is ever called into a senior executive's office to justify why he or she declined to invest the company's money in a bold but untested idea. The risk avoiders rise slowly and steadily in corporate ranks, producing modest results. They never risk their reputations or career achievement, and when they fail, they fail small and justifiably--"The creative tested well!" or "The candidate had a great GPA from a respected school!"

Most of the time, these people guide companies to outcomes within a safe and expected range, perhaps stealing a point of market share from the competition. Little is risked, lost or gained. But the road to failure is paved with a thousand tiny successes, and while risk avoiders don't fail spectacularly, their companies can. Risk avoiders cannot change quickly enough; they miss threats to their marketplace and are unable to rapidly steer a new course. Blockbuster, Borders, GM, and many other firms were full of risk avoiders who were constantly and modestly successful until they suddenly were not.

Of course, there are many in corporate America who embrace risk, but few do so like Jobs and Disney. If you are a risk taker, you probably do so only part way. You likely don't bet your job, your home and your family's future on your vision. Walt Disney would have lost Mickey Mouse and his home had Snow White failed, and he later borrowed against his own life insurance policy to fund the construction of Disneyland. You don't take that kind of risk, and neither do I.

How much are you willing to risk failure? After being promoted and earning a healthy income, are you inclined to put that at risk to pursue your vision and deliver exceptional results for your employer? Can you defend and support an employee's new idea when their last one failed thoroughly?

The lessons of Walt Disney and Steve Jobs aren't simple or easy. Very few of us have the power to achieve anything close to their level of greatness, but the way we choose to view failure and our willingness to risk what we have achieved is, in my opinion, the defining difference between those who are merely successful and those who bring vital change to their organizations.

Most of us desire success and fear failure. What the stories of Jobs and Disney tell me is that we ought to embrace failure and fear success. The more we succeed and achieve, the less likely we become to accept risks. Jobs and Disney remind me of a Steinbeck quote--one I learned from Epcot's American Adventure (Thanks, Walt!)  Steinbeck was speaking of our nation, but he may have well been speaking to every company and individual who has tasted success:

We now face the danger which in the past has been the most destructive to nations. Success, plenty, comfort and ever-increasing leisure: no dynamic people have ever survived these dangers.

Think Different, indeed!

Yesterday, I became "that guy."  I'm an experienced social media professional, know the dangers of mistaking personal and professional accounts, and had just this week discussed with my team ways to diminish the risks of mixing up accounts when posting to social media sites. And yet, last night I made the classic social media blunder: Thinking I was on my personal Facebook page, I accidentally made a status update that resulted in my employer, USAA, broadcasting an opinion of American Idol's final duo.

It's not that our brand isn't personal or doesn't have personality in social media; in fact, it's not outside the range of possibility that the community managers on my team might decide to start a conversation about American Idol with our members on Facebook. But, that should be a carefully considered post and not something done carelessly.

I rapidly deleted my post, but not before it garnered some "likes" and a few comments, both positive and negative. Then, moments later, someone added a comment to the USAA wall asking if a Facebook administrator had just mistakenly posted a personal thought to the corporate fan page. Guilty! I fessed up (with my real name) and apologized. I got some nice supporting comments (since our members are the best and are willing to forgive), and life went on.

I'm ashamed and asked my community managers to (literally) slap my hands with a ruler, but they didn't because they're the best and are also willing to forgive. But, I learned a couple lessons worth sharing:

• Have a personal filter:  The fact you are responsible for a company's social media profile doesn't mean everything you say personally has to reflect the brand's personality, but you must consider the implications of your posts. First, once you are officially associated with a brand, anything you say in your Twitter or other social media streams can reflect upon your employer. Plus, there's always the chance you pull an Augie and mix your personal thoughts into the company's channel.
  
  My mistake could've been the stuff of headlines--the reason you're reading about my mistake here on my personal blog rather than on ABCNews.com is that the tone and content of my erroneous update were mildly, not wildly, off the mark for my employer's fan page. This is because I have a personal filter. I strive to keep things positive in my social media interactions, so even when I post something negative ("I liked American Idol better before it became Country Idol..."), I attempt to include an equal portion of positivity ("...but both of the finalists earned their way here with hard work.")  If you set a personal social media filter and avoid criticizing entire cities, dropping an F-bomb, or mocking a news organization for blathering, you diminish the risks to both your employer and to you.
• Keep them separated:  With apologies to The Offspring, you gotta keep 'em separated--your personal and professional social media tools, that is.  For Twitter management, it is too easy to set up both your personal and professional accounts in a single Twitter client such as HootSuite or Tweetdeck. Doing so is a recipe for danger. Use different Twitter clients for different purposes, and you'll greatly reduce the risk.
  
  Unfortunately. Facebook doesn't easily allow for that sort of separation. If you are the admin for a page, you will post as that page when on the fan page and will post as an individual elsewhere. Since your wall looks a lot like your company's wall, it is easy to fail to notice when you're on one page rather than another, resulting in errant status updates.  One solution is to use a third-party Facebook management tool (which is what we do at USAA), but most administrators still check their fan page in a browser, and therein lies the danger. There isn't much of a solution other than taking care (more than I did), but Facebook could certainly help matters by making your posting state more evident and controllable.

My infraction was minor and the repercussions negligible; I get to keep my job. You may not be so lucky--if you say the wrong thing in the wrong channel, you wouldn't be the first person to lose your job over a seemingly simple mistake. Protect yourself by reconsidering the personal filters and standards you bring to your social media interactions, and sever your personal and professional accounts as much as possible. Doing so could protect your company's reputation--and your job!

The blogosphere is full of horrifying examples of customer service and commentaries about the dangers of ignoring customers in an era when one pissed-off person can distribute their experience to thousands (or ten million).  A friend shared just such an example--a response he received from model company Revell, Inc. It demonstrates a problem common among companies nowadays: Brands don't face social media PR disasters as a result of isolated mistakes but instead create reputation problems with a preventable and cascading series of careless decisions and actions.

In recent years, I've spoken with many corporate leaders who convey a sense of victimization about social media. On the one hand, they have no choice but to be present and part of the conversation; on the other hand, there is almost a feeling of powerlessness and exploitation about the influence that social media gives complainers and detractors.

There are aspects of this feeling that are accurate--no matter how great the investment in quality assurance and first-rate customer service, some customers are bound to be disappointed and spew complaints in social venues.  Even superior companies like Disney, Harley-Davidson and my employer, USAA, are bound to disappoint occasionally. A company cannot welcome 25 million guests at its resort, sell a quarter million bikes or serve the financial needs of 8 million members without falling short of customer expectations on occasion.

While it's true social media has given a larger voice to the average consumer, the impact of this can be overestimated because corporate leaders may obsess about the things they cannot control while failing to act on those things they can. The three things that companies tend to underestimate as levers at their disposal in the face of social media complaints are:

• It's not the mistake that matters but how you handle it:  Mistakes happen. No one expects a company with thousands of employees selling millions of products to bat a thousand. What hurts reputation isn't the mistake but what you do next. The insult that companies add to injury is the fuel that fires social media PR disasters.
    
• Damage is multiplied when many consumers share similar issues: A single complainer can launch a critical and inflammatory tweet to thousands of followers, but what happens next depends on the overall state of your brand and quality of customer service. If the brand generally makes people happy and enjoys a strong sense of affinity with consumers, that tweet likely falls on deaf ears or may even spark a defensive response from brand advocates. But if the brand has wronged many or is suffering from poor perception, others will be inclined to retweet and turn a single complaint into a sizable number of negative brand impressions.
  
  
• Size matters--different situations require different handling:  The one caveat to the first two points is that size matters in two ways. First, the size of a person's influence cannot be ignored--a relatively minor complaint voiced by someone who has true social media influence (and not just 10,000 followers on Twitter) carries more weight. Is this fair to companies targeted by upset influencers? No, but who said life was fair? Secondly, the greater the size of the damage inflicted on a consumer, the larger the risk to reputation. A single rude encounter with a customer service representative is unacceptable but barely nicks a brand's reputation; however, a single mistake that creates a major or lasting problem for a customer greatly increases the risk that a single complaint gains traction and goes viral. Larger complaints or complaints from larger influencers demand special handling.
  

This is to acknowledge receipt of your email.

We are at a loss to explain why these parts were missing out of this kit.

The first course of action would have been to return it to the store for either an exchange or refund.  However, you choose to start painting your model before doing an inventory of the parts. 

Revell kits are subjected to extensive quality checks during the manufacturing process to ensure they leave the factory in perfect condition.  Because these kits go through a packing line there would be no way that the (chrome) could be missing from the kit without someone catching it at the end of the packaging line.

Anytime a product is assembled the (chrome) is usually the second to last part that gets packed into the box; then the (body) is laid on top of all the parts.  Upon opening this kit you would have know that the chrome was missing out of it, immediately.  At that time you should have returned it back to the store.    Unfortunately, you had already started to paint this model.  Therefore, we will be unable to replace this kit.

However, we will be more than happy to help you obtain the (chrome parts) for it.  There is a processing fee in order to receive them that we require in advance.  The fee is $15.00.  Please remit payment by Money Order (no other form of payment will be accepted) payable to Revell Inc.  Please include a copy of this email to insure proper handling of your request.

Mail to: Revell Inc; Attn: Replacement Parts (-85-4291); 1850 Howard Street, Unit A; Elk Grove Village, IL 60007

We ask that you not mail in the kit to us as it will be sent back and no replacement kit will be in order.

Once payment is received here in our office we will then process an order for you to receive these parts.

Thanking you in advance for your payment.

How many mistakes did you catch in this response?  My list includes:

• Business rather than personal language ("This is to acknowledge receipt of your email.")
• No apology.
• No empathy.
• Attempt to convince the customer the mistake couldn't have happened, and in doing so...
• ... subtly accuses the customer of lying or being mistaken.
• Blames the customer for mishandling the situation caused by the company's mistake. ("At that time you should have returned it back to the store.")
• Conveys a robot-like attitude by sending a form message with template tags intact! Note the fill-in-the-blank parenthetical sections: "...no way that the (chrome) could be missing... the (chrome) is usually the second to last part that gets packed into the box; then the (body) is laid on top."
• Turns a customer service problem into a sales opportunity by offering to solve the problem for $15.
• Makes it difficult and time consuming to even act upon the unacceptable solution offered--the company requires a money order rather than an easy form of payment.
• Implies the customer lacks the intelligence to follow instruction ("We ask that you not mail in the kit to us as it will be sent back and no replacement kit will be in order.")
• Ends a service email with the expectation the customer will pay the fee and does so in the impersonal and passive voice ("Thanking you in advance for your payment").

Where the web site acknowledges mistakes can happen, the response to my friend does not. And where the Revell site commits to replacing the part for free, the company's response breaks this promise and demands a payment for the missing part. Does the Revell web site purposely misstate its intentions in an attempt to mislead potential purchasers, or did a renegade customer service rep take it upon herself to try to turn this situation into a revenue-generating opportunity?  The significant difference between the promised and actual experiences causes me to wonder if Revell rewards its service reps for generating sales, which would of course undermine the company's commitment to customer service.

Revell had several opportunities to avoid being the subject of this blog post. The company could've sold a complete model kit, could've lived up to the promises it makes, and could've sent a more personal and caring message. To become a social media problem, Revell didn't make one mistake but many. Revell had all the pieces to construct model customer service, but it ignored its own set of instructions.

Companies must recognize the opportunities and risks inherent in their handling of customer service issues. From "United Breaks Guitars" to Dooce's Maytag woes to my friend's Revell model, it isn't a single mistake that creates negative social media impressions but a failure to handle customers' problems with honesty, transparency, empathy and a commitment to do what is right. Getting your reputation right in social media doesn't require you to avoid making mistakes but to avoid multiplying them.