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WHITE PAPER




                       Why All Organizations Need to
                     Manage and Archive Social Media
ON                                                An Osterman Research White Paper
                                                                               Published April 2012
                                      sponsored by
                 sponsored by
                                      sponsored by


                                      sponsored by

                                        sponsored by
          SPON




                                     sponsored by

                   sponsored by
                                                                                  Osterman Research, Inc.
                                                P.O. Box 1058 • Black Diamond, Washington • 98010-1058 • USA
                                  Tel: +1 253 630 5839 • Fax: +1 253 458 0934 • info@ostermanresearch.com
                                                         www.ostermanresearch.com • twitter.com/mosterman
Why All Organizations Need to
                                                                                             Manage and Archive Social
                                                                                             Media

EXECUTIVE SUMMARY
Social media is among the most pervasive and fastest growing application categories:
roughly one in every eight people on earth has an account with Facebook, the most
popular social media property. In 2011, 48 hours worth of video were uploaded to
YouTube each minute, up from eight hours per minute in 2007i. Facebook took 852
days to reach 10 million users, whereas Google+ took only 16 days to hit this user
countii.

Osterman Research’s own statistics indicate that social media is used heavily in the
workplace: a surveyiii conducted during the first quarter of 2012 found that the
average employee spends 28 minutes per day using social media during work hours
(not counting time spent away from work), or 2.9 workweeks annually. And, while
there are many benefits to social media in the workplace, there are also risks, as the
same survey found:

•   24% of organizations have had malware infiltrations through Facebook, 7%
    through Twitter, and 7% through LinkedIn.
                                                                                             Osterman
•   13% had experienced the leakage of sensitive or confidential information
    through Facebook, 9% through Twitter and 10% through LinkedIn.                           Research’s own
                                                                                             statistics indicate
•   73% to 79% of organizations do not archive their users’ content posted to these
    “Big Three” social media properties.                                                     that social media
                                                                                             is used heavily in
•   13% of organizations have terminated an employee because of something they
    posted on a social media site.                                                           the workplace: a
                                                                                             survey conducted
Despite the problems associated with the use of social media, 81% of organizations
allow the use of Facebook, or have a policy limiting or prohibiting its use that goes        during the first
unenforced. The same applies for 84% of organizations with regard to Twitter – it’s          quarter of 2012
94% for LinkedIn. Moreover, only 19% of organizations have deployed enterprise-
grade social media platforms. By “enterprise-grade” social media, we distinguish it
                                                                                             found that the
from “public” tools like Twitter or Facebook to mean a dedicated social media                average employee
platform that has been deployed specifically for use by employees, business partners
and others.
                                                                                             spends 28
                                                                                             minutes per day
KEY TAKEAWAYS                                                                                using social
While social media can be extremely useful, its use must be managed properly just
like any other corporate communications, collaboration, or information-sharing tool.         media during
Toward that end, there are five things that organizations must do:                           work hours.
•   Create, enforce and update policies focused on appropriate use of social media.

•   Archive business records in social media streams that might be required to
    ensure regulatory or legal compliance.

•   Monitor incoming social media content for malware and other threats that could
    steal corporate data, financial assets or cause other problems.

•   Monitor outbound social media data streams to prevent sensitive data or
    offensive content from being sent from corporate resources.

•   Consider implementing an enterprise-grade social media platform in addition to
    “public” platforms like Facebook and Twitter to help address these other issues.

ABOUT THIS WHITE PAPER
This white paper discusses the various risks that organizations face from unmanaged
use of social media. It also offers advice on how organizations can mitigate these
risks while at the same time realizing the competitive advantages that the use of




©2012 Osterman Research, Inc.                                                            1
Why All Organizations Need to
                                                                                                Manage and Archive Social
                                                                                                Media
social media can offer. Finally, it offers a brief overview of the five sponsors of this
document – Actiance, Erado, GWAVA, Smarsh and Socialtext – and their relevant
offerings.



RAPID GROWTH IN THE USE OF SOCIAL MEDIA
GROWING USE OF “PUBLIC” SOCIAL MEDIA
Leading “public” – or non-enterprise – social media platforms are widely used and are
growing in popularity as evidenced by published statistics:

•   Facebook, the most widely used social media tool, had 166.0 million US visitors
    in November 2011iv. The company reports that it had 845 million monthly active
    users and 483 million daily active users as of December 2011v; iCrossing
    estimates Facebook will reach one billion active users by August 2012vi.

•   Google Sites, whose traffic was mostly generated by YouTube, had 147.2 million
    unique US viewers in May 2011 (2.2 billion viewing sessions) who each averaged
    311 minutes of viewingvii.

•   LinkedIn had 35.0 million US visitors in November 2011viii.

•   Twitter had 35.4 million US visitors in November 2011ix, an increase of 8.4 million         Communication
    from May 2011x. As of mid-March 2012, Twitter had 526.2 million registered                  within social
    accountsxi.
                                                                                                media is
•   Tumblr had 15.9 million US visitors in November 2011xii, up 10.7 million from               displacing a
    May 2011xiii.
                                                                                                growing
•   Pinterest had nearly five million unique US visitors in November 2011xiv and                proportion of
    roughly 20 million users in March 2012xv.
                                                                                                traditional modes
As evidence of the growing importance of social media in the context of just its                of commun-
messaging capabilities, an Ovum study found that text messaging is on the decline as
a result of messages sent via social media – down 6% in 2010 and 9% in 2011xvi.
                                                                                                ication.
This by no means implies that use of mobile platforms is waning – in fact, mobile is
becoming more important – but rather that communication within social media is
displacing a growing proportion of traditional modes of communication like text
messaging.

GROWING USE OF ENTERPRISE SOCIAL MEDIA
An Osterman Research survey conducted during the first quarter of 2012 found that
19% of the organizations surveyed have deployed an enterprise-grade social media
platform. This is significantly below the level of use for consumer-focused tools, such
as Facebook (used by 36% of employees on corporate networks), YouTube (30%),
LinkedIn (29%) and Twitter (17%).

That said, there are a substantial number of corporate users of enterprise social
media platforms, including Jive’s 15 million usersxvii, Yammer’s four million users as of
February 2012 (up from 1.6 million at the end of 2011xviii), Socialtext’s 6,500+
corporate customersxix, Salesforce.com Chatter’s roughly three million users, and
IBM’s many millions of Connections users.

WHERE IS ENTERPRISE SOCIAL MEDIA GOING FROM HERE?
Despite the comparatively low use of enterprise-grade social media platforms at
present, Osterman Research anticipates significant growth in the market for these
tools as a result of two key drivers:

•   Decision makers are increasingly realizing the value of social media for
    collaboration, knowledge sharing, skills discovery and a variety of other




©2012 Osterman Research, Inc.                                                               2
Why All Organizations Need to
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                                                                                               Media
    purposes; and are considering social media as a means of improving employee
    productivity and increasing the speed of decision-making, and thereby delivering
    a competitive advantage. As evidence, the survey cited above found that while
    only 14% of organizations have conducted any sort of return-on-investment
    analysis for social media, another 39% indicated that they need to do so,
    implying that many decision makers view social media as a business productivity
    tool.

•   Decision makers are beginning to realize the significant level of threats that they
    face from the unregulated use of non-enterprise tools in a workplace context. As
    a result, they are deploying capabilities to address specific threats as discussed
    later in this white paper, and are deploying enterprise-grade social media
    solutions to address the deficiencies in consumer/free tools.

It is important to understand, however, that consumer/public platforms are not best
suited to deal with enterprise social media requirements and the security concerns
discussed below.                                                                               Managed
                                                                                               properly, social
SOCIAL MEDIA AND THE PARADIGM SHIFT IT                                                         media can create
REPRESENTS                                                                                     a sense of
                                                                                               community and
WHY IS SOCIAL MEDIA SO PERVASIVE?
Social media is incredibly pervasive, consuming large amounts of the time that users           affirmation for
spend online. For example, in November 2011, the average Facebook user spent 394               employees,
minutes on the sitexx, or 13 minutes per day – up 37% from 12 months earlier. Users
of Tumblr.com and Pinterest spent 142 and 88 minutes in November 2011 on each                  business partners
site, respectively.                                                                            and others in
THE USER PERSPECTIVE                                                                           virtually any
A key reason that social media is increasing in popularity, is that it represents a            organization. It
community of like-minded individuals to whom people can turn to both learn and
share (or overshare) information. As one marketing consultant noted about
                                                                                               can provide a
Facebook, “It’s one of the very few experiences that almost always delivers on                 means of
expectations. A Facebook session always includes something that each individual
cares about. It’s much more reliable and friendly than most real friends. Facebook
                                                                                               information
reaffirms connections to clan, tribe, class and community. Facebook might just be              sharing and
the antidote to existential loneliness.”xxi                                                    gathering that is
Similarly, Twitter is akin to a 24x7 water cooler conversation with hundreds or                simply not
thousands of people in whose opinion one might be interested. It provides a                    possible with
connection to others for purposes of both sharing and gathering information in a
manner and breadth that is simply not possible or practical with other types of tools          other corporate
like email or instant messaging.                                                               tools.
THE BUSINESS PERSPECTIVE
Therein lies one of the fundamental benefits of social media from a business
perspective: managed properly, social media can create a sense of community and
affirmation for employees, business partners and others in virtually any organization.
It can provide a means of information sharing and gathering that is simply not
possible with other corporate tools. Moreover, if organizations can create the
appropriate environment within their organization, viewing it as an integral
component of their larger corporate culture, they can speed decision-making and
improve the quality of corporate decisions, they can improve the speed and quality of
customer service, and they can improve the ability and desire of employees to
collaborate more efficiently and effectively, all resulting in a significant competitive
advantage. They can also leverage their employees to serve as an amplification
channel for the messages the company desires to promote on a wider scale.




©2012 Osterman Research, Inc.                                                              3
Why All Organizations Need to
                                                                                             Manage and Archive Social
                                                                                             Media

SOCIAL MEDIA AND THE RISK IT REPRESENTS
MOST ORGANIZATIONS DO NOT HAVE ADEQUATE SOCIAL
MEDIA POLICIES
The vast majority of organizations do not have detailed and thorough social media
policies in place. For example, as shown in the context of other communication and
collaboration tools in use in mid-sized and enterprise environments, the “Big Three”
social media tools rank well behind other tools in terms of the thoroughness of the
policies that have been implemented to protect against misuse, as shown in the
following figure from a July 2011 reportxxii published by Osterman Research.


Thoroughness of Corporate Policies for Various Systems




                                                                                             The vast majority
                                                                                             of organizations
                                                                                             do not have
                                                                                             detailed and
                                                                                             thorough social
                                                                                             media policies in
                                                                                             place. Even
                                                                                             where policies
                                                                                             exist, many
                                                                                             organizations do
                                                                                             not enforce
                                                                                             compliance rules
                                                                                             in a methodical
Moreover, even where policies exist, many organizations do not enforce compliance
                                                                                             and meaningful
rules in a methodical and meaningful way. For example, Osterman Research found in            way.
a survey conducted during the first quarter of 2012 that only 13% to 20% of
organizations monitor posts to Facebook, Twitter and LinkedIn, and enforce
corporate compliance rules. Further, 76% to 83% of organizations either ask
individuals to comply with corporate policies focused on Facebook, Twitter and
LinkedIn but do not screen for content, or they do nothing.

THERE IS ENORMOUS POTENTIAL FOR MALWARE
INFILTRATION
Among the chief threats that organizations face from unmanaged use of social media
is the potential – and reality – of social media used for ingress of malware. As shown
in the following figure, Osterman Research has found that malware has infiltrated
24% of organizations through Facebook and 7% of organizations through Twitter and
LinkedIn. More troubling, however, is the fact that a large proportion of
organizations simply are not sure whether or not malware has entered through these
tools.




©2012 Osterman Research, Inc.                                                            4
Why All Organizations Need to
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                                                                                           Media
Infiltration of Malware Through Various Social Media Tools
“Has malware ever infiltrated your corporate network through the following tools?”




                                                                                           While traditional
                                                                                           anti-virus and
                                                                                           anti-malware
                                                                                           tools can be
                                                                                           somewhat
                                                                                           effective at
                                                                                           blocking threats,
While traditional anti-virus and anti-malware tools can be somewhat effective at
blocking these threats, a zero-hour threat detection and remediation capability is
                                                                                           a zero-hour
essential to block malware that can enter through social media, including those that       threat detection
can enter through mobile device where a substantial proportion of social media use         and remediation
occurs. Among the various types of malware that can be introduced into an
organization through the unfettered use of social media:                                   capability is
•   Koobface
                                                                                           essential to block
    This worm targets primarily Facebook, but also Twitter, MySpace and other social       malware that can
    media sites. Its goal is to gather login information for purposes of building a        enter through
    peer-to-peer botnet.
                                                                                           social media.
•   Bugat
    Related to the infamous keystroke-logging malware Zeus, Bugat has been
    delivered in a large-scale phishing attack against LinkedIn.

•   Boonana
    Written in Java and first reported in late October 2010, Boonana targets Macs
    and operates much like Koobface.

BUSINESS RECORDS IN SOCIAL MEDIA ARE NOT BEING
ARCHIVED
Another serious problem with current management of social media is that the vast
majority of organizations are not yet archiving their social media content, such as
Facebook posts or tweets. This, despite the growing number of regulations, court
decisions and other guidance that strongly suggests that social media content should
be archived like email or instant messages. For example, among the many regulatory
requirements to archive social media content are the following:

•   Various rules issued by the Financial Industry Regulatory Authority (FINRA)
    require supervision of communications by registered financial services
    representatives. For example, FINRA Regulatory Notice 10-06 states that “Every
    firm that intends to communicate, or permit its associated persons to
    communicate, through social media sites must first ensure that it can retain



©2012 Osterman Research, Inc.                                                          5
Why All Organizations Need to
                                                                                              Manage and Archive Social
                                                                                              Media
    records of those communications as required by Rules 17a-3 and 17a-4 under
    the Securities Exchange Act of 1934 and NASD Rule 3110.” FINRA issued
    Regulatory Notice 11-39 (Social Media Websites and the Use of Personal Devices
    for Business Communications) in August 2011 that addresses questions raised by
    firms that are affected by 10-06.

•   The Securities and Exchange Commission (SEC) published a National
    Examination Risk Alert (Investment Adviser Use of Social Media) on January 4,
    2012 that spells out investment advisers’ obligation related to the use of social
    media. On the same day, the SEC issued sanctions against an individual who,
    although not a registered broker-dealer, used social media to make offers for the
    purchase and sale of fraudulent financial productsxxiii.

•   According to FRCP rules, all employee-created social media content that is work-
    related, regardless of whether or not it was created on a personal account, is
    discoverable. Not only should this be archived and supervised according to
    corporate policies, but archiving this data in a siloed bin may be required to
    address employee privacy issues.

•   The National Archives and Record Administration (NARA) continues to refine
    policy regarding the retention of social media communication. An October 2010
    NARA bulletin explains that “Open and transparent government increasingly                 According to
    relies on the use of these [Web 2.0] technologies, and as agencies adopt these            FRCP rules, all
    tools, they must comply with all records management laws, regulations, and
    policies. The principles for analyzing, scheduling, and managing records are              employee-created
    based on content and are independent of the medium; where and how an                      social media
    agency creates, uses, or stores information does not affect how agencies identify
    Federal records.xxiv”                                                                     content that is
                                                                                              work-related,
•   The US Department of Defense has provided formal guidance on the use of Web
    2.0 tools, which includes guidance that “all users of these Internet-based                regardless of
    capabilities must be aware of the potential record value of their content,                whether or not it
    including content that may originate outside the agency.”
                                                                                              was created on a
•   The Environmental Protection Agency has published Interim Guidance for EPA                personal
    Employees who are Representing EPA Online Using Social Media, requiring that
    “agency records created or received using social media tools must be printed to           account, is
    paper and managed according to the applicable records schedule in a                       discoverable.
    recordkeeping system.”

•   The US State Department’s official policy, Using Social Media, requires a site
    sponsor to be the record keeper for content that must be preserved long term,
    requiring that records “be maintained with related records or managed through
    an acceptable records management application.”

•   While the healthcare industry has thus far received relatively guidance
    specifically on point for social media retention or management, existing
    regulations would seem to apply to social media. For example, if a physician or
    other healthcare professional posts content about a patient to a social media
    site, HIPAA or Federal Substance Abuse Confidentiality laws may apply in the
    context of receiving and retaining patient approval to post this contentxxv.

Several recent legal cases have also underscored the growing importance of retaining
social media content:

•   Smizer v. Cmty. Mennonite Early Learning Ctr.xxvi
    In this case, the defendant claimed that the plaintiff was terminated because of
    an inappropriate post on Facebook, a claim that the plaintiff denied. The Court
    agreed with the plaintiff, ordering discovery of other relevant information and not
    accepting at face value the defendant’s claim that the Facebook post was the
    sole reason for the termination.



©2012 Osterman Research, Inc.                                                             6
Why All Organizations Need to
                                                                                                Manage and Archive Social
                                                                                                Media
•   Katiroll Co. v. Kati Roll & Platters, Inc.xxvii
    The plaintiff sent the defendant a notice asking them to take down certain
    Facebook pages. After the defendant did so, the plaintiff asked the Court for
    sanctions against the defendant for spoliation because the defendant had not
    preserved the pages in PDF format. This case is particularly interesting because
    the Court acknowledged the obligation to preserve content posted to social
    media Web sites. Specifically, the Court found that “given that Defendants have
    a discovery obligation to produce them (the Facebook pages) and that only
    Defendants knew when the website would be changed, it is more appropriate for
    Defendants to have that burden.”

•   Lester v. Allied Concrete Co.xxviii
    The Court fined an attorney $522,000 for telling his client to delete various
    images from his Facebook and Myspace profiles. The client was fined $180,000
    for following the advice to destroy evidence.

Underscoring the growing importance of social media in legal cases is one study that
found 674 federal and state court decisions that involved social media evidence for
the 22-month period ended November 1, 2011xxix.
                                                                                                Underscoring the
                                                                                                growing
SOME EMPLOYEES MISUSE SOCIAL MEDIA                                                              importance of
Another serious threat that organizations face is the misuse of social media by
employees. For example:                                                                         social media in
                                                                                                legal cases is one
•   In 2009, an employee of Ketchum, a public relations firm, used Twitter to post
    insulting comments about the city of Memphis shortly before presenting to the               study that found
    worldwide communications group at FedEx – Memphis’ largest employer. An                     674 federal and
    employee of FedEx discovered the tweet, responded to the tweeter, and then
    copied FedEx’s senior managers, the management of FedEx’s communication                     state court
    department and the management of Ketchumxxx.                                                decisions that
•   Employees at the Tri-City Medical Center in Oceanside, California posted patient            involved social
    information on Facebookxxxi.                                                                media evidence
•   The president of The Redner Group, the (now former) public relations firm for 2K            for the 22-month
    Games’ Duke Nukem Forever tweeted in June 2011 “Too many went too far with                  period ended
    their reviews … we are reviewing who gets games next time and who doesn’t
    based on today’s venom,” publicly threatening to blacklist those who negatively
                                                                                                November 1,
    reviewed the gamexxxii.                                                                     2011.
•   In 2009, authorities investigated a situation in which election exit poll results for
    three German states were leaked on Twitter prior to the polls closingxxxiii.

•   A hospital employee in Hawaii with access to patients’ medical records illegally
    accessed another person’s records and posted on MySpace that the individual
    had HIVxxxiv.

A West Allis, Wisconsin employee was fired for a post she made on her Facebook
page claiming that she was addicted to alcohol and various prescription and illegal
drugs, although the employee claimed that her comments were made in jestxxxv.



HOW SHOULD SOCIAL MEDIA BE MANAGED?
Osterman Research believes that there are five important issues that decision makers
must consider in the context of their social media management:

1. DETERMINE BENEFITS AND HOW BEST TO MANAGE RISKS
    An organization should determine if it can obtain competitive advantage through
    the use of social media – whether consumer/public or enterprise-grade – instead




©2012 Osterman Research, Inc.                                                               7
Why All Organizations Need to
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                                                                                              Media
    of making a knee-jerk decision not to use these tools because of security or
    other risks they might pose.

    To evaluate this question, an organization’s various business units and its IT
    department should conduct a complete evaluation of how social media is used by
    various functions across the enterprise, which tools are used and why they are
    used. This audit should also include an analysis of how these tools might be
    used in the future, how competing firms are using them, and any new
    capabilities that might be required in the future.

    Such an evaluation could reveal that there is a major disconnect between what
    IT, security or compliance perceives as a legitimate application of social media
    and what individual users or business units perceive to be legitimate. The goal is
    to balance the interests of both groups and derive the greatest benefit from the
    use of social media while still remaining compliant with corporate policies and           Implement
    security requirements. For example, specific applications of social media
    discovered in this analysis might include:                                                policies that will
                                                                                              focus on creating
    •    Marketing, communications, PR teams and spokespeople who want the
         ability to post commentary, create events and use the full functionality of          an appropriate
         social media.                                                                        balance between
    •    Corporate users, such as Human Resources and legal staff who need to                 employee
         research new hires and investigate shared content.                                   freedom to
    •    Regulatory compliance teams who must not only maintain records of shared             gather infor-
         content and activities, but also approve and moderate subject matter.                mation and
    •    Employees who utilize social media to prospect for business, network with
                                                                                              communicate via
         customers and partners and collaborate with suppliers.                               social media, the
    •    The analysis might also reveal the need for an enterprise-grade social media
                                                                                              business benefits
         capability to enhance employee productivity, improve customer support, or            that will be
         improve decision making by increasing the velocity and availability of
         information throughout the company.
                                                                                              derived from the
                                                                                              use of these tools,
2. DEVELOP, ENFORCE AND UPDATE SOCIAL MEDIA                                                   compliance with
   POLICIES
    The next step is to implement policies that will focus on creating an appropriate
                                                                                              industry
    balance between employee freedom to gather information and communicate via                regulations, and
    social media, the business benefits that will be derived from the use of these
    tools, compliance with industry regulations, and advice from legal counsel. A
                                                                                              advice from legal
    social media policy should be considered regardless of whether the company                counsel.
    chooses to use consumer/public tools or if it determines that an enterprise
    networking solution is best. Considerations for these policies should include:

    •    Adding social media as part of the overall policy set
         Policies focused on the use of social media tools should be a key part of an
         overall messaging and communication policy that focuses on the use of
         corporate email, personal Webmail, instant messaging tools, collaborative
         workspaces, cloud-based storage tools and any other capability through
         which individuals might share corporate information.

    •    Policy granularity
         Sufficient granularity should be provided in these policies so that differing
         roles within the organization are clearly subject to different policies. For
         example, energy and securities traders may be subject to different rules
         about their use of social media than clerical staff, senior managers should be
         subject to different policies when communicating with external auditors than
         when they communicate with employees, formal communications that




©2012 Osterman Research, Inc.                                                             8
Why All Organizations Need to
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                                                                                               Media
         represent a company position should be subject to different scrutiny than
         personal communications, and so on.

    •    Acceptable use
         Corporate social media policies should include a detailed discussion about
         appropriate use of social media tools, including requirements not to post
         sexually or racially offensive comments or images, not to include links to
         inappropriate Web sites, not to defame or slander others, not to post
         content that could run afoul of copyright laws, not to post personnel records
         or other sensitive information, to ensure that posts are in good taste, and
         the like.

    •    Identifying specific tools that can and cannot be used
         Specific tools that can and cannot be used should be specified clearly,
         preferably along with a rationale for the decision. This includes the social
         media sites themselves, as well as the platforms on which these sites are
         accessed – home computers, smartphones, desktop computers at work, etc.               Corporate
         While some decision makers may opt for a draconian approach and create                policies should
         policies that prohibit the use of Facebook, Twitter, LinkedIn or other tools on
         corporate platforms, such an approach will be unlikely to work and will               clearly state that
         simply prompt employees to use their personal devices to access these                 management
         tools. Instead, a more reasonable approach of allowing appropriate use of
         these tools will better serve management and employees.                               reserves the right
                                                                                               to monitor
    •    The right to monitor
         Corporate policies should clearly state that management reserves the right            employee
         to monitor employee communication via social media, when it has the right             communication
         to act on this information, and that content may be retained for an indefinite
         period.                                                                               via social media,
                                                                                               when it has the
    •    Succession planning
         Some discussion of succession planning should also be a part of social media          right to act on
         policies. For example, when an employee leaves the organization, the                  this information,
         corporate policy should include provisions about “ownership” of the followers
         or friends of that employee. For example, do followers on Twitter belong to           and that content
         the employer or employee? Are an employee’s Facebook posts the property               may be retained
         of his or her employer if they were posted during work hours?
                                                                                               for an indefinite
    •    Data breaches                                                                         period.
         Social media policies should also spell out the corporate reaction to a data
         breach and the consequences of a policy violation. For example, if an
         employee mistakenly tweets a product announcement a day before the
         press release is issued, or mistakenly posts trade secrets on a Facebook
         page, what are the consequences?

3. MANAGE SOCIAL MEDIA APPROPRIATELY
    For any type of social media tool, every organization should deploy technologies
    that will do various things:

    •    Monitor posts, tweets and other outbound content
         Employee posts on every social media protocol that might be used should be
         monitored for content that violates corporate, regulatory or legal policies –
         particularly in heavily regulated industries. This monitoring may be after the
         fact, such as sampling employee posts to check for inappropriate content; or
         it might be in real-time to monitor posts before they leave the organization.

    •    Scan for and remediate malware
         It is also important to block threats that can enter an organization through
         social media. This is particularly important given a) the widespread use of
         shortened URLs that offer the user no visual cues about the veracity of the
         link, and b) the fact that many social media tools can display content



©2012 Osterman Research, Inc.                                                              9
Why All Organizations Need to
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                                                                                                Media
         provided by individuals to whom users have not given permission to display
         posts.

         One of the fundamental problems with social media from a security
         perspective is that these tools are generally less well defended than more
         established tools like email. Given the rapid increase in the use of many of
         these tools, many IT departments are scrambling to keep up with the rapid
         growth of social media tools, leaving organizations vulnerable to malware
         infiltration. As noted earlier, nearly one in four organizations has been the
         victim of Facebook-related malware. In fact, a recent Osterman Research
         survey found that in addition to Facebook, organizations have had malware
         infiltrate through a variety of social media tools, including YouTube and
         Google+.

         Using an enterprise-grade social media platform will alleviate many of these
         concerns.

    •    Archive business records in social media
         It is critical to archive and log all content that might constitute a business         One of the
         record and that might need to be retained for long periods. It is normally
         easier to archive or log all social media content than take the risk that some         fundamental
         important content might slip through and not be retained, but this will                problems with
         depend to a large extent on the industry in which an organization operates,
         management’s tolerance for risk, advice of legal counsel and other factors.            social media
         An important part of content logging is to ensure that the identity of the             from a security
         individuals who use social media tools is clear and that content can be tied
         back to their corporate identity.                                                      perspective is
                                                                                                that these tools
         An important best practice is to integrate social media archiving with email
         and other content archiving. This ensures that legal holds, as well as                 are generally less
         searching for content during early case assessment and e-discovery, are                well defended
         much easier, less time-consuming and less prone to missing important
         content. Many enterprise platforms will be able to handle the archival                 than more
         requirements of an enterprise. Shifting conversations from public open                 established tools
         forums to an internal social intranet will also ensure that risky conversations
         take place behind the firewall rather than in the public eye.                          like email.
4. CONSIDER ANALYTICS
    One of the more important benefits of social media is that it provides a wealth of
    information that can be used to help organizations understand their markets and
    to improve decision-making. For example, by mining data from tweets and
    Facebook posts and performing both text and sentiment analysis on this
    unstructured data, decision makers can gain insight into how their customers
    and prospects are reacting to changes in a product, advertising campaign, price
    change or any number of other issues. The value of analytics when applied to
    social media data is that – unlike traditional market or marketing research –
    social media analytics provides the ability to monitor and analyze a market in
    near real-time. Analytics will become increasingly important with the growth of
    social media because it allows rapid and granular decision-making.

5. CONSIDER DEPLOYING ENTERPRISE SOCIAL MEDIA
    All organizations should consider deploying enterprise-grade social media
    platforms. One of the fundamental benefits of leading enterprise tools is that
    they are purpose-built to protect against the key issues outlined above that
    organizations face from unmanaged use of social media – namely, security,
    archiving of content, permissions controls and compliance. Because enterprise-
    grade platforms do not have their origin in the consumer/free space where these
    types of controls are a lower priority, enterprise tools are built from the ground
    up to provide robust protection and management tools. This ensures that




©2012 Osterman Research, Inc.                                                              10
Why All Organizations Need to
                                                                                               Manage and Archive Social
                                                                                               Media
    organizations can minimize the risks they face when using only consumer/free
    tools.

    That said, it is important to note that we are not advocating an either-or decision
    on the use of enterprise-grade social media tools or those that are aimed at the
    consumer/free market. Moreover, enterprise-grade social media is not a
    panacea for every type of threat, such as malware delivered via mobile devices.
    Osterman Research firmly believes that organizations should deploy both types
    of capabilities:

    •    Enterprise-grade social media tools are designed primarily to improve
         collaboration within an organization; to improve the quality and speed of
         decision-making; to create content like wikis, blogs and collaborative
         documents; to enable improved access to the skill sets of employees across
         an organization; to integrate social content with CRM tools; to improve the
         flow, quality and timeliness of information between employees and business
         partners; and to mitigate the disadvantage of distance for employees who
         work in geographically separate locations.

    •    Consumer/free tools like Facebook or Twitter, on the other hand, are more
         useful for broadcasting content to external parties like customers, prospects
         and others; for marketing brands and establishing industry leadership; and
         for understanding the dynamics of a market through analysis of social media
         information flows. However, these tools require appropriate security,
         archiving and other management capabilities to ensure that their use
         provides the same level of protection as those built into enterprise-grade
         systems.

    It is also important to note that there is some convergence occurring between
    these capabilities, such as enterprise-grade platforms integrating Twitter and
    other social media feeds.



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Actiance ensures the secure and compliant use of UC and Web 2.0 technologies,
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©2012 Osterman Research, Inc.                                                             11
Why All Organizations Need to
                                                                                               Manage and Archive Social
                                                                                               Media
Erado delivers a hosted, social media compliance solution that captures and delivers
social media content (LinkedIn, Facebook, Twitter, Google+, blog content, and more)
to our clients archive and surveillance solutions regardless of the vendor.
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It features real time collection of social media content from the social media sites
regardless of how it was posted, addressing the problem of capturing social media              www.erado.com
content from mobile devices, iptv's and other employee owned or non-monitored
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equipment.
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Erado is one of the nation's fastest growing business-tech companies, and the
nation's premier provider of SaaS based archiving of electronic communications. We
provide a suite of patent pending hosted solutions for capture, review, analytics, and
archiving of electronic communications, including email, instant messaging, social
networking, text messaging, and more. Founded in 1994, Erado helps organizations
manage and enforce cost-effective compliance and records retention policies. For
more information, please call us at 866-67ERADO or visit us at www.erado.com.




For over 10 years, GWAVA has been focused on message security – providing anti-
spam and anti-virus protection for email; backup, restore and archiving of digital
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Messaging has changed from simply email to include texting, instant messaging,                 www.gwava.com
collaboration and social media. You need to keep it, track it, and manage all of it. No
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matter where it comes from or where it resides. All while dealing with the increasing
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messages of thousands of organizations around the world. GWAVA products back up,               questions@gwava.com
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With GWAVA as your message security partner, you will be able to respond to the
rapidly changing definition of what is important to your organizations’
communications. A knowledgeable and friendly worldwide support team is always
available to respond to your needs, no matter when or where you may be.

GWAVA has offices in the United States, Canada, Germany, Great Britain and
Australia. We support Microsoft, Novell, Research in Motion, and other enterprise
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Smarsh® provides hosted solutions for archiving electronic communications,
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©2012 Osterman Research, Inc.                                                             12
Why All Organizations Need to
                                                                                                            Manage and Archive Social
                                                                                                            Media
like LinkedIn, Facebook, and Twitter, and enterprise-grade social media platforms,
with compliance peace of mind.




Socialtext accelerates business performance by making it easier for employees to find
the colleagues and information they need to solve challenges new and old. By
simplifying people's ability to share expertise, ideas and corporate data, Socialtext
removes knowledge silos that have traditionally hampered companies' ability to                              www.socialtext.com
respond to change and serve customers efficiently. With Socialtext, people                                  twitter.com/socialtext
collaborate openly around key business processes in a secure, internal environment,                         facebook.com/ socialtext
and work together to drive new business opportunities.                                                      info@socialtext.com

Established in 2002, Socialtext was the first company to deliver social software to                         +1 877 438 9454
businesses. Now backed by Draper Fisher Jurvetson, Omidyar Networks and                                     +1 650 323 0800
University Venture Fund, our founders realized that the innovations and social
dynamics of consumer services on the web could be adapted for use inside the
enterprise. Inside Socialtext, your employees have easy-to-use, collaborative tools
with the same look and feel of sites like Wikipedia, Facebook and Twitter right at
their fingertips. As a company, Socialtext thrives on a culture of innovation that
emphasizes finding the best assets of the Web and re-purposing them in a way that
makes sense for our customers, their employees, and their IT requirements. The Web
has taught us that expectations for software and user experience can change
overnight. Socialtext has proven time and again that we are the vendor that can best
keep pace with that change. At the same time, we work diligently to fulfill the
stringent security and integration needs of enterprise IT.




© 2012 Osterman Research, Inc. All rights reserved.

No part of this document may be reproduced in any form by any means, nor may it be
distributed without the permission of Osterman Research, Inc., nor may it be resold or
distributed by any entity other than Osterman Research, Inc., without prior written authorization
of Osterman Research, Inc.

Osterman Research, Inc. does not provide legal advice. Nothing in this document constitutes
legal advice, nor shall this document or any software product or other offering referenced herein
serve as a substitute for the reader’s compliance with any laws (including but not limited to any
act, statue, regulation, rule, directive, administrative order, executive order, etc. (collectively,
“Laws”)) referenced in this document. If necessary, the reader should consult with competent
legal counsel regarding any Laws referenced herein. Osterman Research, Inc. makes no
representation or warranty regarding the completeness or accuracy of the information contained
in this document.

THIS DOCUMENT IS PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND. ALL EXPRESS OR
IMPLIED REPRESENTATIONS, CONDITIONS AND WARRANTIES, INCLUDING ANY IMPLIED
WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, ARE
DISCLAIMED, EXCEPT TO THE EXTENT THAT SUCH DISCLAIMERS ARE DETERMINED TO BE
ILLEGAL.




©2012 Osterman Research, Inc.                                                                          13
Why All Organizations Need to
                                                                                                              Manage and Archive Social
                                                                                                              Media

i
         http://searchenginewatch.com/article/2073962/New-YouTube-Statistics-48-Hours-of-Video-
         Uploaded-Per-Minute-3-Billion-Views-Per-Day
ii
         http://www.jeffbullas.com/2011/09/02/20-stunning-social-media-statistics/
iii
         Social Media Market Trends, 2011-2014; Osterman Research, Inc.
iv
         http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html
v
         http://newsroom.fb.com/content/default.aspx?NewsAreaId=22
vi
         http://www.allfacebook.com/facebook-billion-2012-01
vii
         http://www.comscore.com/Press_Events/Press_Releases/2011/6/comScore_Releases_May_2
         011_U.S._Online_Video_Rankings
viii
         http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html
ix
         http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html
x
         http://blog.comscore.com/2011/06/facebook_linkedin_twitter_tumblr.html
xi
         http://twopcharts.com/twitter500million.php
xii
         http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html
xiii
         http://blog.comscore.com/2011/06/facebook_linkedin_twitter_tumblr.html
xiv
         http://blog.comscore.com/2011/12/
xv
         http://www.usatoday.com/tech/news/story/2012-03-30/cnbc-pinterest-growth/53893824/1
xvi
         http://www.tomsguide.com/us/text-message-social-texting-apps,news-14237.html
xvii
         http://elatewiki.org/index.php/Jive/_OffiSync_Software
xviii
         http://www.forbes.com/sites/tomiogeron/2012/02/29/yammer-raises-85-million-in-new-
         funding/
xix
         http://finance.yahoo.com/news/socialtext-continues-momentum-increase-profitability
         -110000175.html
xx
         http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html
xxi
         http://manhattanmarketingmaven.blogs.com/mmm/2012/02/the-psychology-of
         -facebook.html
xxii
         Messaging Policy Market Trends, 2011-2014; Osterman Research, Inc.
xxiii
         http://www.sec.gov/news/digest/2012/dig010412.htm
xxiv
         NARA Bulletin 2011-02
xxv
         http://www.corporatecomplianceinsights.com/think-before-you-tweet-risks-health-care
         -professionals-face-with-social-media/
xxvi
         Smizer v. Cmty. Mennonite Early Learning Ctr., 2011 U.S. Dist. LEXIS 102212, at *1-2 (N.D.
         Ill. Sept. 7, 2011)
xxvii
         Katiroll Co. v. Kati Roll & Platters, Inc., 2011 U.S. Dist. LEXIS 85212, 1-2 (D.N.J. Aug. 3,
         2011)
xxviii
         Lester v. Allied Concrete Co., Nos. 08-015 and 09-223 (Va., Charlottesville Jud. Cir. Dec. 9,
         2010)
xxix
         http://blog.x1discovery.com/2011/11/09/674-published-cases-involving-social-media
         -evidence/
xxx
         http://shankman.com/be-careful-what-you-post/
xxxi
         Source: Privacy Rights Clearinghouse (http://www.privacyrights.org/data-breach)
xxxii
         http://www.zdnet.com/blog/gamification/twitter-tantrum-sinks-duke-nukem-forever-pr
         -agency/472
xxxiii
         http://www.hollywoodreporter.com/news/germany-probes-twitter-election-data-88306
xxxiv
         Source: Privacy Rights Clearinghouse (http://www.privacyrights.org/data-breach)
xxxv
         http://www.courthousenews.com/2010/05/24/27513.htm




©2012 Osterman Research, Inc.                                                                            14

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Why All Organizations Need to Manage and Archive Social Media

  • 1. WHITE PAPER Why All Organizations Need to Manage and Archive Social Media ON An Osterman Research White Paper Published April 2012 sponsored by sponsored by sponsored by sponsored by sponsored by SPON sponsored by sponsored by Osterman Research, Inc. P.O. Box 1058 • Black Diamond, Washington • 98010-1058 • USA Tel: +1 253 630 5839 • Fax: +1 253 458 0934 • info@ostermanresearch.com www.ostermanresearch.com • twitter.com/mosterman
  • 2. Why All Organizations Need to Manage and Archive Social Media EXECUTIVE SUMMARY Social media is among the most pervasive and fastest growing application categories: roughly one in every eight people on earth has an account with Facebook, the most popular social media property. In 2011, 48 hours worth of video were uploaded to YouTube each minute, up from eight hours per minute in 2007i. Facebook took 852 days to reach 10 million users, whereas Google+ took only 16 days to hit this user countii. Osterman Research’s own statistics indicate that social media is used heavily in the workplace: a surveyiii conducted during the first quarter of 2012 found that the average employee spends 28 minutes per day using social media during work hours (not counting time spent away from work), or 2.9 workweeks annually. And, while there are many benefits to social media in the workplace, there are also risks, as the same survey found: • 24% of organizations have had malware infiltrations through Facebook, 7% through Twitter, and 7% through LinkedIn. Osterman • 13% had experienced the leakage of sensitive or confidential information through Facebook, 9% through Twitter and 10% through LinkedIn. Research’s own statistics indicate • 73% to 79% of organizations do not archive their users’ content posted to these “Big Three” social media properties. that social media is used heavily in • 13% of organizations have terminated an employee because of something they posted on a social media site. the workplace: a survey conducted Despite the problems associated with the use of social media, 81% of organizations allow the use of Facebook, or have a policy limiting or prohibiting its use that goes during the first unenforced. The same applies for 84% of organizations with regard to Twitter – it’s quarter of 2012 94% for LinkedIn. Moreover, only 19% of organizations have deployed enterprise- grade social media platforms. By “enterprise-grade” social media, we distinguish it found that the from “public” tools like Twitter or Facebook to mean a dedicated social media average employee platform that has been deployed specifically for use by employees, business partners and others. spends 28 minutes per day KEY TAKEAWAYS using social While social media can be extremely useful, its use must be managed properly just like any other corporate communications, collaboration, or information-sharing tool. media during Toward that end, there are five things that organizations must do: work hours. • Create, enforce and update policies focused on appropriate use of social media. • Archive business records in social media streams that might be required to ensure regulatory or legal compliance. • Monitor incoming social media content for malware and other threats that could steal corporate data, financial assets or cause other problems. • Monitor outbound social media data streams to prevent sensitive data or offensive content from being sent from corporate resources. • Consider implementing an enterprise-grade social media platform in addition to “public” platforms like Facebook and Twitter to help address these other issues. ABOUT THIS WHITE PAPER This white paper discusses the various risks that organizations face from unmanaged use of social media. It also offers advice on how organizations can mitigate these risks while at the same time realizing the competitive advantages that the use of ©2012 Osterman Research, Inc. 1
  • 3. Why All Organizations Need to Manage and Archive Social Media social media can offer. Finally, it offers a brief overview of the five sponsors of this document – Actiance, Erado, GWAVA, Smarsh and Socialtext – and their relevant offerings. RAPID GROWTH IN THE USE OF SOCIAL MEDIA GROWING USE OF “PUBLIC” SOCIAL MEDIA Leading “public” – or non-enterprise – social media platforms are widely used and are growing in popularity as evidenced by published statistics: • Facebook, the most widely used social media tool, had 166.0 million US visitors in November 2011iv. The company reports that it had 845 million monthly active users and 483 million daily active users as of December 2011v; iCrossing estimates Facebook will reach one billion active users by August 2012vi. • Google Sites, whose traffic was mostly generated by YouTube, had 147.2 million unique US viewers in May 2011 (2.2 billion viewing sessions) who each averaged 311 minutes of viewingvii. • LinkedIn had 35.0 million US visitors in November 2011viii. • Twitter had 35.4 million US visitors in November 2011ix, an increase of 8.4 million Communication from May 2011x. As of mid-March 2012, Twitter had 526.2 million registered within social accountsxi. media is • Tumblr had 15.9 million US visitors in November 2011xii, up 10.7 million from displacing a May 2011xiii. growing • Pinterest had nearly five million unique US visitors in November 2011xiv and proportion of roughly 20 million users in March 2012xv. traditional modes As evidence of the growing importance of social media in the context of just its of commun- messaging capabilities, an Ovum study found that text messaging is on the decline as a result of messages sent via social media – down 6% in 2010 and 9% in 2011xvi. ication. This by no means implies that use of mobile platforms is waning – in fact, mobile is becoming more important – but rather that communication within social media is displacing a growing proportion of traditional modes of communication like text messaging. GROWING USE OF ENTERPRISE SOCIAL MEDIA An Osterman Research survey conducted during the first quarter of 2012 found that 19% of the organizations surveyed have deployed an enterprise-grade social media platform. This is significantly below the level of use for consumer-focused tools, such as Facebook (used by 36% of employees on corporate networks), YouTube (30%), LinkedIn (29%) and Twitter (17%). That said, there are a substantial number of corporate users of enterprise social media platforms, including Jive’s 15 million usersxvii, Yammer’s four million users as of February 2012 (up from 1.6 million at the end of 2011xviii), Socialtext’s 6,500+ corporate customersxix, Salesforce.com Chatter’s roughly three million users, and IBM’s many millions of Connections users. WHERE IS ENTERPRISE SOCIAL MEDIA GOING FROM HERE? Despite the comparatively low use of enterprise-grade social media platforms at present, Osterman Research anticipates significant growth in the market for these tools as a result of two key drivers: • Decision makers are increasingly realizing the value of social media for collaboration, knowledge sharing, skills discovery and a variety of other ©2012 Osterman Research, Inc. 2
  • 4. Why All Organizations Need to Manage and Archive Social Media purposes; and are considering social media as a means of improving employee productivity and increasing the speed of decision-making, and thereby delivering a competitive advantage. As evidence, the survey cited above found that while only 14% of organizations have conducted any sort of return-on-investment analysis for social media, another 39% indicated that they need to do so, implying that many decision makers view social media as a business productivity tool. • Decision makers are beginning to realize the significant level of threats that they face from the unregulated use of non-enterprise tools in a workplace context. As a result, they are deploying capabilities to address specific threats as discussed later in this white paper, and are deploying enterprise-grade social media solutions to address the deficiencies in consumer/free tools. It is important to understand, however, that consumer/public platforms are not best suited to deal with enterprise social media requirements and the security concerns discussed below. Managed properly, social SOCIAL MEDIA AND THE PARADIGM SHIFT IT media can create REPRESENTS a sense of community and WHY IS SOCIAL MEDIA SO PERVASIVE? Social media is incredibly pervasive, consuming large amounts of the time that users affirmation for spend online. For example, in November 2011, the average Facebook user spent 394 employees, minutes on the sitexx, or 13 minutes per day – up 37% from 12 months earlier. Users of Tumblr.com and Pinterest spent 142 and 88 minutes in November 2011 on each business partners site, respectively. and others in THE USER PERSPECTIVE virtually any A key reason that social media is increasing in popularity, is that it represents a organization. It community of like-minded individuals to whom people can turn to both learn and share (or overshare) information. As one marketing consultant noted about can provide a Facebook, “It’s one of the very few experiences that almost always delivers on means of expectations. A Facebook session always includes something that each individual cares about. It’s much more reliable and friendly than most real friends. Facebook information reaffirms connections to clan, tribe, class and community. Facebook might just be sharing and the antidote to existential loneliness.”xxi gathering that is Similarly, Twitter is akin to a 24x7 water cooler conversation with hundreds or simply not thousands of people in whose opinion one might be interested. It provides a possible with connection to others for purposes of both sharing and gathering information in a manner and breadth that is simply not possible or practical with other types of tools other corporate like email or instant messaging. tools. THE BUSINESS PERSPECTIVE Therein lies one of the fundamental benefits of social media from a business perspective: managed properly, social media can create a sense of community and affirmation for employees, business partners and others in virtually any organization. It can provide a means of information sharing and gathering that is simply not possible with other corporate tools. Moreover, if organizations can create the appropriate environment within their organization, viewing it as an integral component of their larger corporate culture, they can speed decision-making and improve the quality of corporate decisions, they can improve the speed and quality of customer service, and they can improve the ability and desire of employees to collaborate more efficiently and effectively, all resulting in a significant competitive advantage. They can also leverage their employees to serve as an amplification channel for the messages the company desires to promote on a wider scale. ©2012 Osterman Research, Inc. 3
  • 5. Why All Organizations Need to Manage and Archive Social Media SOCIAL MEDIA AND THE RISK IT REPRESENTS MOST ORGANIZATIONS DO NOT HAVE ADEQUATE SOCIAL MEDIA POLICIES The vast majority of organizations do not have detailed and thorough social media policies in place. For example, as shown in the context of other communication and collaboration tools in use in mid-sized and enterprise environments, the “Big Three” social media tools rank well behind other tools in terms of the thoroughness of the policies that have been implemented to protect against misuse, as shown in the following figure from a July 2011 reportxxii published by Osterman Research. Thoroughness of Corporate Policies for Various Systems The vast majority of organizations do not have detailed and thorough social media policies in place. Even where policies exist, many organizations do not enforce compliance rules in a methodical Moreover, even where policies exist, many organizations do not enforce compliance and meaningful rules in a methodical and meaningful way. For example, Osterman Research found in way. a survey conducted during the first quarter of 2012 that only 13% to 20% of organizations monitor posts to Facebook, Twitter and LinkedIn, and enforce corporate compliance rules. Further, 76% to 83% of organizations either ask individuals to comply with corporate policies focused on Facebook, Twitter and LinkedIn but do not screen for content, or they do nothing. THERE IS ENORMOUS POTENTIAL FOR MALWARE INFILTRATION Among the chief threats that organizations face from unmanaged use of social media is the potential – and reality – of social media used for ingress of malware. As shown in the following figure, Osterman Research has found that malware has infiltrated 24% of organizations through Facebook and 7% of organizations through Twitter and LinkedIn. More troubling, however, is the fact that a large proportion of organizations simply are not sure whether or not malware has entered through these tools. ©2012 Osterman Research, Inc. 4
  • 6. Why All Organizations Need to Manage and Archive Social Media Infiltration of Malware Through Various Social Media Tools “Has malware ever infiltrated your corporate network through the following tools?” While traditional anti-virus and anti-malware tools can be somewhat effective at blocking threats, While traditional anti-virus and anti-malware tools can be somewhat effective at blocking these threats, a zero-hour threat detection and remediation capability is a zero-hour essential to block malware that can enter through social media, including those that threat detection can enter through mobile device where a substantial proportion of social media use and remediation occurs. Among the various types of malware that can be introduced into an organization through the unfettered use of social media: capability is • Koobface essential to block This worm targets primarily Facebook, but also Twitter, MySpace and other social malware that can media sites. Its goal is to gather login information for purposes of building a enter through peer-to-peer botnet. social media. • Bugat Related to the infamous keystroke-logging malware Zeus, Bugat has been delivered in a large-scale phishing attack against LinkedIn. • Boonana Written in Java and first reported in late October 2010, Boonana targets Macs and operates much like Koobface. BUSINESS RECORDS IN SOCIAL MEDIA ARE NOT BEING ARCHIVED Another serious problem with current management of social media is that the vast majority of organizations are not yet archiving their social media content, such as Facebook posts or tweets. This, despite the growing number of regulations, court decisions and other guidance that strongly suggests that social media content should be archived like email or instant messages. For example, among the many regulatory requirements to archive social media content are the following: • Various rules issued by the Financial Industry Regulatory Authority (FINRA) require supervision of communications by registered financial services representatives. For example, FINRA Regulatory Notice 10-06 states that “Every firm that intends to communicate, or permit its associated persons to communicate, through social media sites must first ensure that it can retain ©2012 Osterman Research, Inc. 5
  • 7. Why All Organizations Need to Manage and Archive Social Media records of those communications as required by Rules 17a-3 and 17a-4 under the Securities Exchange Act of 1934 and NASD Rule 3110.” FINRA issued Regulatory Notice 11-39 (Social Media Websites and the Use of Personal Devices for Business Communications) in August 2011 that addresses questions raised by firms that are affected by 10-06. • The Securities and Exchange Commission (SEC) published a National Examination Risk Alert (Investment Adviser Use of Social Media) on January 4, 2012 that spells out investment advisers’ obligation related to the use of social media. On the same day, the SEC issued sanctions against an individual who, although not a registered broker-dealer, used social media to make offers for the purchase and sale of fraudulent financial productsxxiii. • According to FRCP rules, all employee-created social media content that is work- related, regardless of whether or not it was created on a personal account, is discoverable. Not only should this be archived and supervised according to corporate policies, but archiving this data in a siloed bin may be required to address employee privacy issues. • The National Archives and Record Administration (NARA) continues to refine policy regarding the retention of social media communication. An October 2010 NARA bulletin explains that “Open and transparent government increasingly According to relies on the use of these [Web 2.0] technologies, and as agencies adopt these FRCP rules, all tools, they must comply with all records management laws, regulations, and policies. The principles for analyzing, scheduling, and managing records are employee-created based on content and are independent of the medium; where and how an social media agency creates, uses, or stores information does not affect how agencies identify Federal records.xxiv” content that is work-related, • The US Department of Defense has provided formal guidance on the use of Web 2.0 tools, which includes guidance that “all users of these Internet-based regardless of capabilities must be aware of the potential record value of their content, whether or not it including content that may originate outside the agency.” was created on a • The Environmental Protection Agency has published Interim Guidance for EPA personal Employees who are Representing EPA Online Using Social Media, requiring that “agency records created or received using social media tools must be printed to account, is paper and managed according to the applicable records schedule in a discoverable. recordkeeping system.” • The US State Department’s official policy, Using Social Media, requires a site sponsor to be the record keeper for content that must be preserved long term, requiring that records “be maintained with related records or managed through an acceptable records management application.” • While the healthcare industry has thus far received relatively guidance specifically on point for social media retention or management, existing regulations would seem to apply to social media. For example, if a physician or other healthcare professional posts content about a patient to a social media site, HIPAA or Federal Substance Abuse Confidentiality laws may apply in the context of receiving and retaining patient approval to post this contentxxv. Several recent legal cases have also underscored the growing importance of retaining social media content: • Smizer v. Cmty. Mennonite Early Learning Ctr.xxvi In this case, the defendant claimed that the plaintiff was terminated because of an inappropriate post on Facebook, a claim that the plaintiff denied. The Court agreed with the plaintiff, ordering discovery of other relevant information and not accepting at face value the defendant’s claim that the Facebook post was the sole reason for the termination. ©2012 Osterman Research, Inc. 6
  • 8. Why All Organizations Need to Manage and Archive Social Media • Katiroll Co. v. Kati Roll & Platters, Inc.xxvii The plaintiff sent the defendant a notice asking them to take down certain Facebook pages. After the defendant did so, the plaintiff asked the Court for sanctions against the defendant for spoliation because the defendant had not preserved the pages in PDF format. This case is particularly interesting because the Court acknowledged the obligation to preserve content posted to social media Web sites. Specifically, the Court found that “given that Defendants have a discovery obligation to produce them (the Facebook pages) and that only Defendants knew when the website would be changed, it is more appropriate for Defendants to have that burden.” • Lester v. Allied Concrete Co.xxviii The Court fined an attorney $522,000 for telling his client to delete various images from his Facebook and Myspace profiles. The client was fined $180,000 for following the advice to destroy evidence. Underscoring the growing importance of social media in legal cases is one study that found 674 federal and state court decisions that involved social media evidence for the 22-month period ended November 1, 2011xxix. Underscoring the growing SOME EMPLOYEES MISUSE SOCIAL MEDIA importance of Another serious threat that organizations face is the misuse of social media by employees. For example: social media in legal cases is one • In 2009, an employee of Ketchum, a public relations firm, used Twitter to post insulting comments about the city of Memphis shortly before presenting to the study that found worldwide communications group at FedEx – Memphis’ largest employer. An 674 federal and employee of FedEx discovered the tweet, responded to the tweeter, and then copied FedEx’s senior managers, the management of FedEx’s communication state court department and the management of Ketchumxxx. decisions that • Employees at the Tri-City Medical Center in Oceanside, California posted patient involved social information on Facebookxxxi. media evidence • The president of The Redner Group, the (now former) public relations firm for 2K for the 22-month Games’ Duke Nukem Forever tweeted in June 2011 “Too many went too far with period ended their reviews … we are reviewing who gets games next time and who doesn’t based on today’s venom,” publicly threatening to blacklist those who negatively November 1, reviewed the gamexxxii. 2011. • In 2009, authorities investigated a situation in which election exit poll results for three German states were leaked on Twitter prior to the polls closingxxxiii. • A hospital employee in Hawaii with access to patients’ medical records illegally accessed another person’s records and posted on MySpace that the individual had HIVxxxiv. A West Allis, Wisconsin employee was fired for a post she made on her Facebook page claiming that she was addicted to alcohol and various prescription and illegal drugs, although the employee claimed that her comments were made in jestxxxv. HOW SHOULD SOCIAL MEDIA BE MANAGED? Osterman Research believes that there are five important issues that decision makers must consider in the context of their social media management: 1. DETERMINE BENEFITS AND HOW BEST TO MANAGE RISKS An organization should determine if it can obtain competitive advantage through the use of social media – whether consumer/public or enterprise-grade – instead ©2012 Osterman Research, Inc. 7
  • 9. Why All Organizations Need to Manage and Archive Social Media of making a knee-jerk decision not to use these tools because of security or other risks they might pose. To evaluate this question, an organization’s various business units and its IT department should conduct a complete evaluation of how social media is used by various functions across the enterprise, which tools are used and why they are used. This audit should also include an analysis of how these tools might be used in the future, how competing firms are using them, and any new capabilities that might be required in the future. Such an evaluation could reveal that there is a major disconnect between what IT, security or compliance perceives as a legitimate application of social media and what individual users or business units perceive to be legitimate. The goal is to balance the interests of both groups and derive the greatest benefit from the use of social media while still remaining compliant with corporate policies and Implement security requirements. For example, specific applications of social media discovered in this analysis might include: policies that will focus on creating • Marketing, communications, PR teams and spokespeople who want the ability to post commentary, create events and use the full functionality of an appropriate social media. balance between • Corporate users, such as Human Resources and legal staff who need to employee research new hires and investigate shared content. freedom to • Regulatory compliance teams who must not only maintain records of shared gather infor- content and activities, but also approve and moderate subject matter. mation and • Employees who utilize social media to prospect for business, network with communicate via customers and partners and collaborate with suppliers. social media, the • The analysis might also reveal the need for an enterprise-grade social media business benefits capability to enhance employee productivity, improve customer support, or that will be improve decision making by increasing the velocity and availability of information throughout the company. derived from the use of these tools, 2. DEVELOP, ENFORCE AND UPDATE SOCIAL MEDIA compliance with POLICIES The next step is to implement policies that will focus on creating an appropriate industry balance between employee freedom to gather information and communicate via regulations, and social media, the business benefits that will be derived from the use of these tools, compliance with industry regulations, and advice from legal counsel. A advice from legal social media policy should be considered regardless of whether the company counsel. chooses to use consumer/public tools or if it determines that an enterprise networking solution is best. Considerations for these policies should include: • Adding social media as part of the overall policy set Policies focused on the use of social media tools should be a key part of an overall messaging and communication policy that focuses on the use of corporate email, personal Webmail, instant messaging tools, collaborative workspaces, cloud-based storage tools and any other capability through which individuals might share corporate information. • Policy granularity Sufficient granularity should be provided in these policies so that differing roles within the organization are clearly subject to different policies. For example, energy and securities traders may be subject to different rules about their use of social media than clerical staff, senior managers should be subject to different policies when communicating with external auditors than when they communicate with employees, formal communications that ©2012 Osterman Research, Inc. 8
  • 10. Why All Organizations Need to Manage and Archive Social Media represent a company position should be subject to different scrutiny than personal communications, and so on. • Acceptable use Corporate social media policies should include a detailed discussion about appropriate use of social media tools, including requirements not to post sexually or racially offensive comments or images, not to include links to inappropriate Web sites, not to defame or slander others, not to post content that could run afoul of copyright laws, not to post personnel records or other sensitive information, to ensure that posts are in good taste, and the like. • Identifying specific tools that can and cannot be used Specific tools that can and cannot be used should be specified clearly, preferably along with a rationale for the decision. This includes the social media sites themselves, as well as the platforms on which these sites are accessed – home computers, smartphones, desktop computers at work, etc. Corporate While some decision makers may opt for a draconian approach and create policies should policies that prohibit the use of Facebook, Twitter, LinkedIn or other tools on corporate platforms, such an approach will be unlikely to work and will clearly state that simply prompt employees to use their personal devices to access these management tools. Instead, a more reasonable approach of allowing appropriate use of these tools will better serve management and employees. reserves the right to monitor • The right to monitor Corporate policies should clearly state that management reserves the right employee to monitor employee communication via social media, when it has the right communication to act on this information, and that content may be retained for an indefinite period. via social media, when it has the • Succession planning Some discussion of succession planning should also be a part of social media right to act on policies. For example, when an employee leaves the organization, the this information, corporate policy should include provisions about “ownership” of the followers or friends of that employee. For example, do followers on Twitter belong to and that content the employer or employee? Are an employee’s Facebook posts the property may be retained of his or her employer if they were posted during work hours? for an indefinite • Data breaches period. Social media policies should also spell out the corporate reaction to a data breach and the consequences of a policy violation. For example, if an employee mistakenly tweets a product announcement a day before the press release is issued, or mistakenly posts trade secrets on a Facebook page, what are the consequences? 3. MANAGE SOCIAL MEDIA APPROPRIATELY For any type of social media tool, every organization should deploy technologies that will do various things: • Monitor posts, tweets and other outbound content Employee posts on every social media protocol that might be used should be monitored for content that violates corporate, regulatory or legal policies – particularly in heavily regulated industries. This monitoring may be after the fact, such as sampling employee posts to check for inappropriate content; or it might be in real-time to monitor posts before they leave the organization. • Scan for and remediate malware It is also important to block threats that can enter an organization through social media. This is particularly important given a) the widespread use of shortened URLs that offer the user no visual cues about the veracity of the link, and b) the fact that many social media tools can display content ©2012 Osterman Research, Inc. 9
  • 11. Why All Organizations Need to Manage and Archive Social Media provided by individuals to whom users have not given permission to display posts. One of the fundamental problems with social media from a security perspective is that these tools are generally less well defended than more established tools like email. Given the rapid increase in the use of many of these tools, many IT departments are scrambling to keep up with the rapid growth of social media tools, leaving organizations vulnerable to malware infiltration. As noted earlier, nearly one in four organizations has been the victim of Facebook-related malware. In fact, a recent Osterman Research survey found that in addition to Facebook, organizations have had malware infiltrate through a variety of social media tools, including YouTube and Google+. Using an enterprise-grade social media platform will alleviate many of these concerns. • Archive business records in social media It is critical to archive and log all content that might constitute a business One of the record and that might need to be retained for long periods. It is normally easier to archive or log all social media content than take the risk that some fundamental important content might slip through and not be retained, but this will problems with depend to a large extent on the industry in which an organization operates, management’s tolerance for risk, advice of legal counsel and other factors. social media An important part of content logging is to ensure that the identity of the from a security individuals who use social media tools is clear and that content can be tied back to their corporate identity. perspective is that these tools An important best practice is to integrate social media archiving with email and other content archiving. This ensures that legal holds, as well as are generally less searching for content during early case assessment and e-discovery, are well defended much easier, less time-consuming and less prone to missing important content. Many enterprise platforms will be able to handle the archival than more requirements of an enterprise. Shifting conversations from public open established tools forums to an internal social intranet will also ensure that risky conversations take place behind the firewall rather than in the public eye. like email. 4. CONSIDER ANALYTICS One of the more important benefits of social media is that it provides a wealth of information that can be used to help organizations understand their markets and to improve decision-making. For example, by mining data from tweets and Facebook posts and performing both text and sentiment analysis on this unstructured data, decision makers can gain insight into how their customers and prospects are reacting to changes in a product, advertising campaign, price change or any number of other issues. The value of analytics when applied to social media data is that – unlike traditional market or marketing research – social media analytics provides the ability to monitor and analyze a market in near real-time. Analytics will become increasingly important with the growth of social media because it allows rapid and granular decision-making. 5. CONSIDER DEPLOYING ENTERPRISE SOCIAL MEDIA All organizations should consider deploying enterprise-grade social media platforms. One of the fundamental benefits of leading enterprise tools is that they are purpose-built to protect against the key issues outlined above that organizations face from unmanaged use of social media – namely, security, archiving of content, permissions controls and compliance. Because enterprise- grade platforms do not have their origin in the consumer/free space where these types of controls are a lower priority, enterprise tools are built from the ground up to provide robust protection and management tools. This ensures that ©2012 Osterman Research, Inc. 10
  • 12. Why All Organizations Need to Manage and Archive Social Media organizations can minimize the risks they face when using only consumer/free tools. That said, it is important to note that we are not advocating an either-or decision on the use of enterprise-grade social media tools or those that are aimed at the consumer/free market. Moreover, enterprise-grade social media is not a panacea for every type of threat, such as malware delivered via mobile devices. Osterman Research firmly believes that organizations should deploy both types of capabilities: • Enterprise-grade social media tools are designed primarily to improve collaboration within an organization; to improve the quality and speed of decision-making; to create content like wikis, blogs and collaborative documents; to enable improved access to the skill sets of employees across an organization; to integrate social content with CRM tools; to improve the flow, quality and timeliness of information between employees and business partners; and to mitigate the disadvantage of distance for employees who work in geographically separate locations. • Consumer/free tools like Facebook or Twitter, on the other hand, are more useful for broadcasting content to external parties like customers, prospects and others; for marketing brands and establishing industry leadership; and for understanding the dynamics of a market through analysis of social media information flows. However, these tools require appropriate security, archiving and other management capabilities to ensure that their use provides the same level of protection as those built into enterprise-grade systems. It is also important to note that there is some convergence occurring between these capabilities, such as enterprise-grade platforms integrating Twitter and other social media feeds. SPONSORS OF THIS WHITE PAPER ! The Socialite platform helps Financial Institutions protect brand and ensure compliance while allowing employees to share relevant content, measure impact and increase engagement. www.actiance.com Enterprise needs for social enablement follow a hierarchy of requirements, the twitter.com/actiance fundamental foundation of this is the requirement for compliance - followed by facebook.com/actiance integration with existing business systems and processes. Content, convenience and info@actiance.com usability are critical to success, which becomes apparent once compliance is in place. Socialite Enable provides feature and content security and compliance for +1 888 349 3223 Facebook, LinkedIn and Twitter, providing granular control of more than 200 features +1 650 631 6300 and content areas. Socialite Enable also provides pre approval, management and archiving of content shared and activities undertaken. Socialite Engage helps Financial Advisors share relevant and pre-approved content, ensure authenticity of voice, measure impact and increase engagement in order to grow their business. Actiance ensures the secure and compliant use of UC and Web 2.0 technologies, including social networks like Facebook and LinkedIn, internal and external blogs, and instant messaging networks for the enterprise. ©2012 Osterman Research, Inc. 11
  • 13. Why All Organizations Need to Manage and Archive Social Media Erado delivers a hosted, social media compliance solution that captures and delivers social media content (LinkedIn, Facebook, Twitter, Google+, blog content, and more) to our clients archive and surveillance solutions regardless of the vendor. ! It features real time collection of social media content from the social media sites regardless of how it was posted, addressing the problem of capturing social media www.erado.com content from mobile devices, iptv's and other employee owned or non-monitored twitter.com/erado equipment. sales@erado.com With Erado's Social Media solution, regulated and non-regulated entities have the ability to engage in social networking compliantly, enhancing your firms bottom line. +1 866 673 7236 +1 425 277 8266! Erado is one of the nation's fastest growing business-tech companies, and the nation's premier provider of SaaS based archiving of electronic communications. We provide a suite of patent pending hosted solutions for capture, review, analytics, and archiving of electronic communications, including email, instant messaging, social networking, text messaging, and more. Founded in 1994, Erado helps organizations manage and enforce cost-effective compliance and records retention policies. For more information, please call us at 866-67ERADO or visit us at www.erado.com. For over 10 years, GWAVA has been focused on message security – providing anti- spam and anti-virus protection for email; backup, restore and archiving of digital messages; and email system management. ! Messaging has changed from simply email to include texting, instant messaging, www.gwava.com collaboration and social media. You need to keep it, track it, and manage all of it. No twitter.com/gwava matter where it comes from or where it resides. All while dealing with the increasing sophistication of cyberterrorists. GWAVA takes on these challenges, securing the facebook.com/gwava messages of thousands of organizations around the world. GWAVA products back up, questions@gwava.com archive and retain electronic messages including email, text and more assuring they are accessible when you need them. Going beyond traditional anti-spam and anti- +1 866 464 9282 virus protection, GWAVA makes sure cyber-criminals cannot corrupt or access your +1 646 304 6250 messages or hijack your organization’s resources. ! With GWAVA as your message security partner, you will be able to respond to the rapidly changing definition of what is important to your organizations’ communications. A knowledgeable and friendly worldwide support team is always available to respond to your needs, no matter when or where you may be. GWAVA has offices in the United States, Canada, Germany, Great Britain and Australia. We support Microsoft, Novell, Research in Motion, and other enterprise infrastructure platforms. Smarsh® provides hosted solutions for archiving electronic communications, including email, instant messaging and social media. The company helps organizations enforce flexible, secure and cost-effective compliance and records ! retention strategies. www.smarsh.com twitter.com/smarshinc The Smarsh platform offers robust supervision, compliance and e-discovery sales@smarsh.com functionality designed to meet the sophisticated needs of highly regulated industries. Social media compliance solutions from Smarsh give organizations of all sizes the +1 866 762 7741 preservation, supervision and policy controls to embrace both public social networks +1 503 946 5980! ©2012 Osterman Research, Inc. 12
  • 14. Why All Organizations Need to Manage and Archive Social Media like LinkedIn, Facebook, and Twitter, and enterprise-grade social media platforms, with compliance peace of mind. Socialtext accelerates business performance by making it easier for employees to find the colleagues and information they need to solve challenges new and old. By simplifying people's ability to share expertise, ideas and corporate data, Socialtext removes knowledge silos that have traditionally hampered companies' ability to www.socialtext.com respond to change and serve customers efficiently. With Socialtext, people twitter.com/socialtext collaborate openly around key business processes in a secure, internal environment, facebook.com/ socialtext and work together to drive new business opportunities. info@socialtext.com Established in 2002, Socialtext was the first company to deliver social software to +1 877 438 9454 businesses. Now backed by Draper Fisher Jurvetson, Omidyar Networks and +1 650 323 0800 University Venture Fund, our founders realized that the innovations and social dynamics of consumer services on the web could be adapted for use inside the enterprise. Inside Socialtext, your employees have easy-to-use, collaborative tools with the same look and feel of sites like Wikipedia, Facebook and Twitter right at their fingertips. As a company, Socialtext thrives on a culture of innovation that emphasizes finding the best assets of the Web and re-purposing them in a way that makes sense for our customers, their employees, and their IT requirements. The Web has taught us that expectations for software and user experience can change overnight. Socialtext has proven time and again that we are the vendor that can best keep pace with that change. At the same time, we work diligently to fulfill the stringent security and integration needs of enterprise IT. © 2012 Osterman Research, Inc. All rights reserved. No part of this document may be reproduced in any form by any means, nor may it be distributed without the permission of Osterman Research, Inc., nor may it be resold or distributed by any entity other than Osterman Research, Inc., without prior written authorization of Osterman Research, Inc. Osterman Research, Inc. does not provide legal advice. Nothing in this document constitutes legal advice, nor shall this document or any software product or other offering referenced herein serve as a substitute for the reader’s compliance with any laws (including but not limited to any act, statue, regulation, rule, directive, administrative order, executive order, etc. (collectively, “Laws”)) referenced in this document. If necessary, the reader should consult with competent legal counsel regarding any Laws referenced herein. Osterman Research, Inc. makes no representation or warranty regarding the completeness or accuracy of the information contained in this document. THIS DOCUMENT IS PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND. ALL EXPRESS OR IMPLIED REPRESENTATIONS, CONDITIONS AND WARRANTIES, INCLUDING ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, ARE DISCLAIMED, EXCEPT TO THE EXTENT THAT SUCH DISCLAIMERS ARE DETERMINED TO BE ILLEGAL. ©2012 Osterman Research, Inc. 13
  • 15. Why All Organizations Need to Manage and Archive Social Media i http://searchenginewatch.com/article/2073962/New-YouTube-Statistics-48-Hours-of-Video- Uploaded-Per-Minute-3-Billion-Views-Per-Day ii http://www.jeffbullas.com/2011/09/02/20-stunning-social-media-statistics/ iii Social Media Market Trends, 2011-2014; Osterman Research, Inc. iv http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html v http://newsroom.fb.com/content/default.aspx?NewsAreaId=22 vi http://www.allfacebook.com/facebook-billion-2012-01 vii http://www.comscore.com/Press_Events/Press_Releases/2011/6/comScore_Releases_May_2 011_U.S._Online_Video_Rankings viii http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html ix http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html x http://blog.comscore.com/2011/06/facebook_linkedin_twitter_tumblr.html xi http://twopcharts.com/twitter500million.php xii http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html xiii http://blog.comscore.com/2011/06/facebook_linkedin_twitter_tumblr.html xiv http://blog.comscore.com/2011/12/ xv http://www.usatoday.com/tech/news/story/2012-03-30/cnbc-pinterest-growth/53893824/1 xvi http://www.tomsguide.com/us/text-message-social-texting-apps,news-14237.html xvii http://elatewiki.org/index.php/Jive/_OffiSync_Software xviii http://www.forbes.com/sites/tomiogeron/2012/02/29/yammer-raises-85-million-in-new- funding/ xix http://finance.yahoo.com/news/socialtext-continues-momentum-increase-profitability -110000175.html xx http://blog.comscore.com/2011/12/state_of_the_us_social_networking.html xxi http://manhattanmarketingmaven.blogs.com/mmm/2012/02/the-psychology-of -facebook.html xxii Messaging Policy Market Trends, 2011-2014; Osterman Research, Inc. xxiii http://www.sec.gov/news/digest/2012/dig010412.htm xxiv NARA Bulletin 2011-02 xxv http://www.corporatecomplianceinsights.com/think-before-you-tweet-risks-health-care -professionals-face-with-social-media/ xxvi Smizer v. Cmty. Mennonite Early Learning Ctr., 2011 U.S. Dist. LEXIS 102212, at *1-2 (N.D. Ill. Sept. 7, 2011) xxvii Katiroll Co. v. Kati Roll & Platters, Inc., 2011 U.S. Dist. LEXIS 85212, 1-2 (D.N.J. Aug. 3, 2011) xxviii Lester v. Allied Concrete Co., Nos. 08-015 and 09-223 (Va., Charlottesville Jud. Cir. Dec. 9, 2010) xxix http://blog.x1discovery.com/2011/11/09/674-published-cases-involving-social-media -evidence/ xxx http://shankman.com/be-careful-what-you-post/ xxxi Source: Privacy Rights Clearinghouse (http://www.privacyrights.org/data-breach) xxxii http://www.zdnet.com/blog/gamification/twitter-tantrum-sinks-duke-nukem-forever-pr -agency/472 xxxiii http://www.hollywoodreporter.com/news/germany-probes-twitter-election-data-88306 xxxiv Source: Privacy Rights Clearinghouse (http://www.privacyrights.org/data-breach) xxxv http://www.courthousenews.com/2010/05/24/27513.htm ©2012 Osterman Research, Inc. 14