Presentation by: Jim Hilsenrod, Director, Strategic Accounts, Actiance, Inc. www.bdionline.com

1. How to Enable Social Media in Financial Services

2. Agenda
Intro
About Actiance
Social Media on the Rise
Benefits of Social Media
Understanding the Risks
Applicable Regulations
Anecdotes
Applying Appropriate Controls
Wrap-up
1 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

3. About Actiance
Enable the New Internet
– 4,500+ Web 2.0 apps, Unified
Communications, Social Networks
Global operations
– USA, EMEA, India, Asia/Pacific
Market Leader
– 9 of the top 10 US banks
– Top 5 Canadian banks
– 3 of the top 5 energy companies
Broadest Partner Ecosystem
– Technology alliances
2 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

4. Social Is Booming
Social Networking
Social Collaboration
Social Publishing
Social Feedback
3 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

5. Upside of Social Media
Generate buzz and increase visibility
Strengthen customer relations
Build an additional revenue source
Extend your brand
4 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

6. Risks of Using Social Media and Web 2.0
Data Leakage Incoming Threats Compliance & eDiscovery User Behavior
Personal SEC, FINRA Employee
Information Malware, Spyware Productivity
HIPAA, FISMA
Intellectual Property Viruses, Trojans Bandwidth
SOX, PCI, FSA
Credit Card, Explosion
Inappropriate
SSN FRCP- eDiscovery
Content Every employee is
Client Records FERC, NERC the face of business

7. Web 2.0 & Social Networks Regulation & Compliance
Regulation Social Network and Web 2.0 Impact
Obliged to store records and make accessible. Public correspondence requires
SEC and FINRA approval, review and retention. Extended to social media.
http://www.finra.org/Industry/Issues/Advertising/p006118
Protect information, monitor for sensitive content, and ensure not sent over
Gramm-Leach-Bliley Act (GLBA) public channels (e.g., Twitter)
Ensuring cardholder data is not sent over unsecured channels AND PROVING
PCI IT
Prevent identity theft. Protect IM and Web 2.0 from malware and phishing
Red Flag Rules when users are more likely to drop their guard.
Email and IM are ESI. Posts to social media sites must be preserved if
FRCP (eDiscovery) reasonably determined to be discoverable. http://blog.twitter.com/
Sarbanes-Oxley (SOX) Businesses must preserve information relevant to the company reporting.

8. Real-Life Anecdotes
Citibank
Deloitte Financial
Northshore Bank
Online Banking
7 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

9. Appropriate Controls: The Basics
Who needs controls applied?
Users within your organization - HR, Marketing, Sales, IT?
How do I apply these controls?
Are there tools available?
Where do I get started?
8 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

10. Appropriate Controls: The Specifics
Issue Control Requirements
Identity management Ensure that all the different logins of an individual link back to corporate identity
Activity control Posting of content allowed for marketing but read-only for everyone else
Granular application control Employees can access Facebook, but not Facebook Chat or Facebook Games
Anti-malware Protect network against hidden phishing or Trojan attacks
Data leak prevention Protect organization from employees disclosing sensitive information
Moderation Messages posted only upon approval by designated officer
Logging and archiving Log all content posted to social networks
Export of data Export stored data to any email archive or WORM storage
9 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

11. Appropriate Controls: Moderation
Posts to Twitter/Facebook/LinkedIn
held for review by the following
criteria:
– All
– Keyword/dictionary matches
– Regular expressions (e.g., credit
card/SSN patterns)
10 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

12. Appropriate Controls: Archiving for eDiscovery
Social networking activity and
posts are captured
All the captured
events are presented
for eDiscovery and
available for export to
archiving platforms
11 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

13. Further Reading and Materials
Osterman Research White Paper
“The Impact of New Communications
Tools for Financial Services Organizations”
Meeting FINRA 10-06 Compliance Guidelines White Paper
How Actiance address FINRA 10-06 Matrix
2010 Internet Usage Survey Results
12 Confidential and Proprietary © 2011, Actiance, Inc. All rights reserved.

14. Questions