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Social Media Assessment
Discussion Document
http://www.youtube.com/watch?v=0eUeL3n7fDs
Copyright © 2012 Deloitte Development LLC. All rights reserved.2 Assessing and auditing social media
Overview of social media
Social media opportunities
Social media risks
Regulatory environment
A risk intelligent approach
Contents
Overview of social media
Copyright © 2012 Deloitte Development LLC. All rights reserved.4 Assessing and auditing social media
Wikipedia:
“Social media includes web- and mobile-based technologies to support interactive dialogue and introduce
substantial and pervasive changes to communication between organizations, communities, and
individuals. Social media are social software which mediate human communication.”
Source: Wikipedia, Social Media, November 12, 2012, http://en.wikipedia.org/wiki/Social_media
Merriam Webster:
“Social media are forms of electronic communication (as Web sites for social networking and
microblogging) through which users create online communities to share information, ideas, personal
messages, and other content (as videos).”
Source: Merriam Webster, November 12, 2012, http://en.wikipedia.org/wiki/Social_media
About.com
“Social media is a type of online media that expedites conversation as opposed to traditional media,
which delivers content but does not allow readers/viewers/listeners to participate in the creation or
development of the content.”
Source: Social Media Definition, Susan Ward, November 12, 2012, http://sbinfocanada.about.com/od/socialmedia/g/socialmedia.htm
Social media is continuing to evolve and so the definition is also changing. Here are some of the
recent definitions.
Social media definition
Copyright © 2012 Deloitte Development LLC. All rights reserved.5 Assessing and auditing social media
Social media Description
Collaboration
A page or site designed to enable collaborative contribution and modification of
content by users
Web Log Communications
(Blogs)
Frequent online publications with commentary on current events, subjects, or
one’s personal thoughts
Social Networking
Site focused on building online communities, establishing connections, and
providing avenues for social interaction
Presence and Microblogging Brief real-time updates of personal commentary, news, or status (aka “Tweets”)
Micro-Media: Online photo and
video sharing
Media-centric online communities that facilitate the viewing, sharing, and
“tagging,” or classification, of media content
Online Review & Opinion
Forums
Websites/Tools that allow users to search for peer reviews or advice on a product
or service, as well as to contribute their own ratings and comments
Social Networking Location
Based Forums
Website applications that allow users to “check in” and locate friends in various
locations, share reviews and earn rewards
Entertainment Social network games or interactive video games
Social media is an umbrella term for a host of sites and technology that facilitates social interaction,
sharing, and creation of user-generated content, and aggregation of users’ opinions and
recommendations.
Common forms of social media
Social media landscape — Popular examples
Copyright © 2012 Deloitte Development LLC. All rights reserved.6 Assessing and auditing social media
Social Media Includes:
Copyright © 2012 Deloitte Development LLC. All rights reserved.7 Assessing and auditing social media
680,747 views per
corporate YouTube
channel
Facts and figures
> 40% of social media
users access content from
their mobile phone
8 out of 10
companies are talked
about on Twitter
What happens in Vegas stays in Social Media
2 2nd largest search
engine in the world is
YouTube
78 78% of consumers trust
opinions of others
> 62% of Fortune 500
Companies have an active
corporate Facebook or
Twitter account
10.5 Billion
Minutes are spent on
Facebook each day
excluding mobile
1
No. 1 Web activity is
Social Media
80% of companies use
social media for recruiting
> 1 Billion
active Facebook users
2.9 Billion
Hours are spent on
YouTube each month
190 190 Million
tweets per day
Sources: Statistics Brain: Social Network Statistics, www.statisticbrain.com/social-networking-statistics
Social Media Revolution 2012, The Total Profit, October 23, 2011, http://www.youtube.com/watch?v=0eUeL3n7fDs
Social media benefits
Copyright © 2012 Deloitte Development LLC. All rights reserved.9 Assessing and auditing social media
Opportunities
Build a brand • Ability to build trust and engage customers through direct communication channels
• Opportunity to grow through increased awareness of the brand
• Better understanding of customer sentiment of the brand
• Ability to proactively monitor and address issues early that surface on social sites
• Customer feedback / dissatisfaction
• Negative press
• Ability for greater favorable perceptions of the brand
• Ratings / Reviews
• Ability to detect early warning signs of potential product or service issues
Marketing • Increased marketing channels and opportunities
• Increased brand awareness among target customers
• Ability to engage in dialogue directly with customers
• Ability to increase traffic to website
• Improved insights about target market
• Ability to identify new product or service opportunities
• Ability to quickly reach the masses at a lower cost than traditional marketing and advertising
Employees • Opportunity to improve operational efficiencies and increase the productivity of employees through
collaboration
• Ability to attract and retain talent
Social media: Opportunities
Copyright © 2012 Deloitte Development LLC. All rights reserved.10 Assessing and auditing social media
Social media
Generate
Prospects
and Leads
(Sales)
1
• Decrease time to market for new products
• Increase marketing effectiveness
• Develop new revenue opportunities
• Leverage “interest” based marketing &
advertising
Decrease
Costs
2
• Decrease R&D costs for new products by
listening to your customers (and prospects)
• Focus on inexpensive social media tools
instead of using the traditional expensive
marketing channels
• Decrease customer support costs
Increase
Loyalty
3 • Increase customer insights and intelligence
(“Voice of Customer”)
• Improve customer experience responsiveness
• Improve customer education, expertise and
service
• Direct contact with the customer instead of
indirect through the retail channels
Manage
Brand
Reputation
4
• Increase brand awareness through social
media
• Protect brand and manage reputation
• Benefit from spontaneous reactions from the
community by connecting like-minded peers
Loss of
Control
1
• The voice of the customer is amplified
• Companies no longer control the message or
topic
• Messages might include negative publicity
Inconsistent
message
2
• When engaging several employees in the
social media world, their messages and
responses may not be consistent and aligned
with the strategy of the company
Confidential
Information
3
• The use of social media sites enables users to
circumvent company controls, opening up the
potential to violate communication policies
• Education and training for employees is a
component to managing loss of information
Productivity
loss
4
• Social media drives collaboration among co-
workers but can also be a major distraction in
the work place
Benefits Challenges
Social media risks
Copyright © 2012 Deloitte Development LLC. All rights reserved.12 Assessing and auditing social media
Social media: Risks
Anticipated risks
Legal and
regulatory compliance
• Disclosure of confidential data (e.g., Personal Health Information, Personally Identifiable
Information)
• Violation of copyright laws
• Protection of intellectual property rights, patents, and trademarks
• Regulatory noncompliance
Security and privacy • Identity theft and social engineering
• Technical exploits: Malware, viruses/worms, Flash vulnerabilities, and XML injection
• Insufficient monitoring capabilities
• Data leakage
Brand and
reputation damage
• Viral video or bad press resulting from a security incident (i.e., loss of data)
• Defamation, unfavorable or untrue posts
• Copyright infringement
• Insufficient monitoring and listening capabilities
Social governance and
strategy
• Lack of policy
• Lack of risk oversight
• Misalignment of social strategy with strategic vision
Employees • Inappropriate use of social media
• Distraction/productivity loss
• Inadequate training and awareness
Copyright © 2012 Deloitte Development LLC. All rights reserved.13 Assessing and auditing social media
Social media risk landscape
Organization
People
Technology
Data
Unauthorized Disclosure
Intellectual Property leakage
Vulnerabilities
Identity Theft
Brand / Reputation Loss
Public
Unsatisfied Constituents
Impact network
availability (DOS)
Virus/
Worms/Trojans
Loss of Productivity
HR Policy Violations
Social Engineering /
Impersonation
Privacy Risk
Trademark Infringement
Loss of Control Over Content
Copyright Issue
Lack of Situational Awareness
Negative Publicity
False Impression/
Misguidance
Regulatory environment
Copyright © 2012 Deloitte Development LLC. All rights reserved.15 Assessing and auditing social media
Regulatory Notice 10–06, 11–39: Guidance on blogs, social networking
websites, and business communications
The goal of the notice is to ensure:
• Investors are protected from false or misleading claims and representations
• Firms are able to effectively and appropriately supervise their associated
persons’ participation in social sites
Financial Industry Regulatory Authority (FINRA)
Sources:
FINRA Regulatory Notice 10-06: Social Media Web Sites: Guidance on Blogs and Social Networking Web Sites, January 2010
FINRA Regulatory Notice 11-39: Social Media Websites and the Use of Personal Devices for Business Communications : Guidance on
Social Networking Websites and Business Communications, August 2011
Copyright © 2012 Deloitte Development LLC. All rights reserved.16 Assessing and auditing social media
Recordkeeping
• Firms are required to retain records of communications for 3 years related to
the broker-dealer’s business that are made through social media sites
• Originals of all communications received and copies of all communications
sent by the member, broker or dealer
• Receipt of each compliant must be acknowledged within 15 business days
Suitability
• Broker-dealers are required to determine that recommendations are suitable
for every investor to whom it is made
Supervision
• Maintain and establish mechanisms to supervise activities of associated
persons to achieve compliance
• Registered principal must review and approve social media sites and
content to be posted (e.g., blogs and social networking sites)
• Associated persons / registered representatives must be trained and not
present undue risk
• Policies and procedures are required
FINRA (cont.)
Copyright © 2012 Deloitte Development LLC. All rights reserved.17 Assessing and auditing social media
Third-party posts
• Customer and third-party posts on social sites established by the firm are not
considered the firm’s communication
• Exceptions
– The firm aided in preparation of the content
– The firm endorses or approves the content
FINRA (cont.)
Copyright © 2012 Deloitte Development LLC. All rights reserved.18 Assessing and auditing social media
Memorandum OM 12–31 from the Office of General Counsel of NLRB emphasized that employee rights
under Section 7 of the National Labor Relations Act (NLRA) must be considered when creating a social
media policy or disciplining an employee for social networking activity.
At issue is whether social media policies violate employees’ right, under Section 7 of the NLRA, to
communicate or work together in “concerted activities” for the purpose of collective bargaining or to
improve working conditions and terms of employment.
Employers in both union and nonunion workplaces who terminate or discipline an employee based on a
social media posting that the NLRB finds to be “protected concerted activity” — such as a Facebook
conversation among employees complaining about pay — may be violating Section 7.
“The Employer’s rule prohibited “making disparaging comments about
the company through any media, including online blogs, other electronic
media or through the media.”
“We concluded that this rule was unlawful because it would reasonably be
construed to restrict Section 7 activity…”
National Labor Relations Board (NLRB)
Sources:
National Labor Relations Act, Rights of Employees, Sec. 7. [§ 157.], National Labor Relations Board
Operations Management Memorandum 12-31, Office of General Counsel of National Labor Relations Board, January 24, 2012
Copyright © 2012 Deloitte Development LLC. All rights reserved.19 Assessing and auditing social media
FTC 16 CFR Part 255 “Guides Concerning the Use of Endorsements and
Testimonials in Advertising”
• Guides address the application of Section 5 of the FTC Act (15 U.S.C. 45)
regarding endorsements and testimonials in advertising
• The guides provide the basis for voluntary compliance with the law by
advertisers and endorsers
• Inconsistent practices with these guides may result in corrective action by
the commission
Federal Trade Commission (FTC)
Source: Federal Trade Commission, 16 CFR Part 255, Guides Concerning the Use of Endorsements and Testimonials in Advertising,
Federal Trade Commission, Final Rule; Notice of adoption of revised Guides, October 2009
Copyright © 2012 Deloitte Development LLC. All rights reserved.20 Assessing and auditing social media
FTC 16 CFR Part 255 “Guides Concerning the Use of Endorsements and
Testimonials in Advertising”
• Endorsements must reflect the honest opinions, findings, beliefs, or
experience of the endorser and may not be deceptive
– Both advertisers and endorsers can be liable for endorser’s statements
• Section 5 requires the disclosure of a connection between an advertiser and
an endorser when the relationship is not apparent within the communication
containing the endorsement.
– For example, an advertiser’s provision of a gift to a blogger for posting blog content
could constitute a material connection that is not reasonably expected by readers of
the blog.
Federal Trade Commission (FTC) (cont.)
Copyright © 2012 Deloitte Development LLC. All rights reserved.21 Assessing and auditing social media
National Examination Alert with investment
adviser considerations for evaluating use of
social media compliance policies:
• Usage guidelines
• Monitoring
• Content standards
• Information security
Details can be found at www.sec.gov
U.S. Securities and Exchange Commission (SEC)
Copyright © 2012 Deloitte Development LLC. All rights reserved.22 Assessing and auditing social media
Federal Financial Institutions Examination
Council (FFIEC)
Social Media: Consumer Compliance Risk Management Guidance
• Financial institutions should have a risk management program
commensurate with the breadth of the financial institution’s involvement in
social media, that allows it to identify, measure, monitor, and control the risks
related to this medium.
• Institutions are to control content on their social media site owned or
administered by a third party and to change policies regarding information
provided through the site.
• Financial institutions should have procedures to address risks from
occurrences such as members of the public posting confidential or sensitive
information.
• Financial institutions’ incident response protocol regarding a security event,
such as a data breach or account takeover, should include social media, as
appropriate.
A risk intelligent approach
Copyright © 2012 Deloitte Development LLC. All rights reserved.24 Assessing and auditing social media
Assessment Approach
Phase III: Design
and discovery
Phase II: Social
Listening
Phase IV: Assess
and analyze
Phase V:
Collaboration
and reporting
Phase I: Planning and
scoping
Activities:
• Identify key internal and
external stakeholders:
Marketing, Product
Development, IT,
Compliance, Legal,
Risk, etc.
• Obtain relevant
documents, strategy,
policies, governance
structure, etc.
• Define/agree on scope
and search criteria
• Identify areas of focus
• Develop a project plan
and time table including
program piloting
strategy
Activities:
• Define search terms:
brands, keywords,
topic points,
comparison
organizations
• Generate social media
research reports
through “listening” and
“risk sensing” tools
• Review raw data and
identify patterns,
anomalies, and areas
for additional focus
Activities:
• Obtain stakeholder feed
of “current state”
through:
– Online surveys
– Workshops
– Publicly available
or privately
subscribed
information
• Review existing social
media and relevant
security policies,
strategies, governance
• Review user access to
owned social sites
• Review regulatory
requirements
• Develop risk
assessment framework
Activities:
• Synthesize responses
• Aggregate the results
using broad themes
• Identify prioritized
emerging risks and
potential impacts from
assessment and
sensing research
• Validate the
observations with the
stakeholders in one on
one interviews
Activities:
• Collaborate with
Deloitte subject matter
experts and
management to stratify
emerging risks,
potential impact
• Develop risk mitigation
response strategies for
risks
• Identify
recommendations
based on insights
gained
• Summarize findings
Milestone:
• Project Plan
Milestone:
• Social media listening
report and high level
insights
Milestone:
• Questionnaires, surveys
or workshops
• Templates
Milestone:
• Summary of preliminary
findings
• Validation meetings
Deliverable:
• Final report on
recommendations and
findings
PhaseKeyActivitiesDeliverables
Copyright © 2012 Deloitte Development LLC. All rights reserved.25 Assessing and auditing social media
Understanding the social media perspective of
the organization
The perspectives below generalize the social media interactions of an organization. It is important to
understand the social media perspective before assessing risk.
Organization — Internal
• Hosted on organization-owned or
controlled technology
• Restricted to organization employees only (in
some special cases to clients and vendors)
Organization — Public
• Hosted on organization-owned technology (like a
CEO blog on organization’s website) or is hosted
by an external provider on their technology
• Open to public
• Sponsored by the organization or one of its
business units in accordance with the
organization policy
Public
• Hosted by an external provider on their technology
• Open to public
• Not sponsored by the organization
Key Risk
considerations
Reputation risk
management
Legal and
regulatory
compliance
Security and privacy
Governance and
strategy
Training and
awareness
Copyright © 2012 Deloitte Development LLC. All rights reserved.26 Assessing and auditing social media
• Who in the organization is responsible for social media: Marketing, Legal, IT, HR, Public Relations, etc.
• Is there a social media center of excellence?
• In what social media channels does the organization have an active presence?
• Has a risk assessment been conducted to identify risks associated with the current use of social
media?
• Is there an established policy (and supporting standards) that addresses social media use?
• Does the policy address all aspects of social media use in the workplace — both business
and personal?
• Have employees been educated on appropriate use of social media and are they aware of the policy?
• Do employees receive periodic awareness communication regarding policies
and risks?
• What technology safeguards are in place?
• Is there risk management oversight of policies and procedures?
• Does a social strategy exist?
Understand the social media landscape of the
organization
Source: Social Media: Business Benefits and Security, Governance and Assurance Perspectives, ISACA, 2010
Copyright © 2012 Deloitte Development LLC. All rights reserved.27 Assessing and auditing social media
Include key areas within the environment and identify stakeholders
Social media activity affects a wide range of business functions within an organization. An effective social
media risk assessment should include key areas affected by the use of social media and the identification
of key stakeholders within those areas who understand the processes and pain points.
Assess the environment
Conduct interviews (or use questionnaires) with key stakeholders to asses current social media practices
and uncover the associated risks with:
• Reputation management
• Governance and strategy
• Legal and regulatory compliance
• Security and privacy
• Training and awareness
Validate risks
Summarize, socialize and agree on risks
Prioritize, develop mitigation strategies and roadmap
Conduct facilitated workshops to rank risks, develop recommendations, prioritize and build a roadmap
Risk assessment approach
• Marketing
• Public relations
• Customer service
• Communications
• Human resources
• Internal audit
• Information technology
• Security
• Legal & compliance
• Risk
• Crisis management
• Other
Copyright © 2012 Deloitte Development LLC. All rights reserved.28 Assessing and auditing social media
Assessment Approach
Phase III: Design
and discovery
Phase II: Social
Listening
Phase IV: Assess
and analyze
Phase V:
Collaboration
and reporting
Phase I: Planning and
scoping
Activities:
• Identify key internal and
external stakeholders:
Marketing, Product
Development, IT,
Compliance, Legal,
Risk, etc.
• Obtain relevant
documents, strategy,
policies, governance
structure, etc.
• Define/agree on scope
and search criteria
• Identify areas of focus
• Develop a project plan
and time table including
program piloting
strategy
Activities:
• Define search terms:
brands, keywords,
topic points,
comparison
organizations
• Generate social media
research reports
through “listening” and
“risk sensing” tools
• Review raw data and
identify patterns,
anomalies, and areas
for additional focus
Activities:
• Obtain stakeholder feed
of “current state”
through:
– Online surveys
– Workshops
– Publicly available
or privately
subscribed
information
• Review existing social
media and relevant
security policies,
strategies, governance
• Review user access to
owned social sites
• Review regulatory
requirements
• Develop risk
assessment framework
Activities:
• Synthesize responses
• Aggregate the results
using broad themes
• Identify prioritized
emerging risks and
potential impacts from
assessment and
sensing research
• Validate the
observations with the
stakeholders in one on
one interviews
Activities:
• Collaborate with
Deloitte subject matter
experts and
management to stratify
emerging risks,
potential impact
• Develop risk mitigation
response strategies for
risks
• Identify
recommendations
based on insights
gained
• Summarize findings
Milestone:
• Project Plan
Milestone:
• Social media listening
report and high level
insights
Milestone:
• Questionnaires, surveys
or workshops
• Templates
Milestone:
• Summary of preliminary
findings
• Validation meetings
Deliverable:
• Final report on
recommendations and
findings
PhaseKeyActivitiesDeliverables
Copyright © 2012 Deloitte Development LLC. All rights reserved.29 Assessing and auditing social media
Approach
Period data was gathered [tbd]
Research Hypothesis Tool Selection Gather Raw Data Insights Investigate
•Company
Name
•Competitors
•Keywords
•Industry
•Ask
Questions
•Look for
information
•Seek sources
•Speculate
•Formulate
•Radian6
•PeopleBrowsr
•Attensity360
•Mutual Mind
•Webtrends
•Google
Analytics
•Google
Trends
•Twitalizer
•PeerIndex
•Klout
•Kred
•Mantis Pulse
•WiseWindow
•Adobe Social
•Bottlenose
•DataSift
•Gnip
•Alterian SM2
•Numbers
•Charts
•Graphs
•Lists
•Pictures
•People
•Interesting
Patterns
•Anomalies
•Why?
•Results
match
business
goals?
•Outside
factors
•What can be
influenced?
• Best ROI
• Fastest
• Easiest
• Most
important
• Most
critical
• Most
strategic
More Research
•Deeper Dive
•New
Questions
•Follow on
answers
Copyright © 2012 Deloitte Development LLC. All rights reserved.30 Assessing and auditing social media
Potential opportunities
Community
Management
§ Tend to the social garden
by facilitating
conversations between
customers, employees,
and partners
§ Assign Community Lead
to manage and set
strategic direction for
Customer Communities
across platforms
§ Analyze community data
to enhance business
strategy and product
development
§ Regularly monitor and
push appropriate content
to Customer & Partner
Communities
Do these resonate? What other focus areas are most impactful to you?
Proactive
Social Support
§ Joining social
conversations to help
inform customers
§ Enabling tools &
resources to monitor
social platforms for
support related events
§ Monitoring, Analyze, &
Address support
related conversations
§ Dedicate a percentage
of support staff time to
mining social channels
for additional support
related events
Voice of Competitor’s
Customers
§ Know what competitors’
products customers are
purchasing and understand
customer purchasing
drivers
§ Configure listening tool to
route these to sales and
marketing for conversions
and campaigns
§ Integrate CRM system with
social listening to create
competitor customer
profiles
§ Identify competitor crises
and establish war room
procedures to quickly act
on competitive advantages.
Social Media
Command Center
§ Set up a Command
Center to monitor and
respond to social trends,
opportunities, and crisis.
§ Evaluate and select social
monitoring, routing and
interaction platforms
§ Formulate organization
response policies to
social crisis and events
§ Train resources for
rotational assignment to
social command and
response teams
Copyright © 2012 Deloitte Development LLC. All rights reserved.31 Assessing and auditing social media
Assessment Approach
Phase III: Design
and discovery
Phase II: Social
Listening
Phase IV: Assess
and analyze
Phase V:
Collaboration
and reporting
Phase I: Planning and
scoping
Activities:
• Identify key internal and
external stakeholders:
Marketing, Product
Development, IT,
Compliance, Legal,
Risk, etc.
• Obtain relevant
documents, strategy,
policies, governance
structure, etc.
• Define/agree on scope
and search criteria
• Identify areas of focus
• Develop a project plan
and time table including
program piloting
strategy
Activities:
• Define search terms:
brands, keywords,
topic points,
comparison
organizations
• Generate social media
research reports
through “listening” and
“risk sensing” tools
• Review raw data and
identify patterns,
anomalies, and areas
for additional focus
Activities:
• Obtain stakeholder feed
of “current state”
through:
– Online surveys
– Workshops
– Publicly available
or privately
subscribed
information
• Review existing social
media and relevant
security policies,
strategies, governance
• Review user access to
owned social sites
• Review regulatory
requirements
• Develop risk
assessment framework
Activities:
• Synthesize responses
• Aggregate the results
using broad themes
• Identify prioritized
emerging risks and
potential impacts from
assessment and
sensing research
• Validate the
observations with the
stakeholders in one on
one interviews
Activities:
• Collaborate with
Deloitte subject matter
experts and
management to stratify
emerging risks,
potential impact
• Develop risk mitigation
response strategies for
risks
• Identify
recommendations
based on insights
gained
• Summarize findings
Milestone:
• Project Plan
Milestone:
• Social media listening
report and high level
insights
Milestone:
• Questionnaires, surveys
or workshops
• Templates
Milestone:
• Summary of preliminary
findings
• Validation meetings
Deliverable:
• Final report on
recommendations and
findings
PhaseKeyActivitiesDeliverables
Copyright © 2012 Deloitte Development LLC. All rights reserved.32 Assessing and auditing social media
Reputation risk management
• Is there an effective crisis management plan for the escalation
of incidents?
• Is customer service involved and are they trained on crisis management?
Legal and regulatory compliance
• What is the landscape of the regulatory environment impacting the
organization (e.g., FINRA, NRLB, FTC, HIPAA )
• Does the policy support the regulatory landscape and do social media
operations comply with the internal policy, legal and regulatory requirements?
• Is the organization’s use of social media in compliance with social media site
policies?
Security and privacy
• Are the security and privacy risks associated with the adoption of social media
being addressed?
• What safeguards are in place to prevent data leakage?
• Are cyber security safeguards in place to detect and prevent threats from
social engineering attacks (e.g., phishing, identify theft)?
Key assessment considerations
Key Risk
considerations
Reputation risk
management
Legal and
regulatory
compliance
Security and privacy
Governance and
strategy
Training and
awareness
Copyright © 2012 Deloitte Development LLC. All rights reserved.33 Assessing and auditing social media
Governance and strategy
• Is there a well-defined and documented strategy?
• Has a cross-functional governance framework been adopted that includes
oversight of policies and adoption of initiatives?
• Is there a policy? (Business versus Personal use)
– If one exists, what’s in it?
• Channels where the organization participates
• Who is authorized to speak on behalf of the organization
• Processes and tools in place to monitor communications by employees, customers
or the public
• Links to other related policies (e.g., acceptable use, handling sensitive data, data
retention)
• Restrictions
• Consequences for noncompliance
– Do employees know about it?
Training and Awareness
• What type of training and education is in place?
• What is the frequency and timing?
• Has an awareness program been adopted?
Key assessment considerations (cont.)
Key Risk
considerations
Reputation risk
management
Legal and
regulatory
compliance
Security and privacy
Governance and
strategy
Training and
awareness
Copyright © 2012 Deloitte Development LLC. All rights reserved.34 Assessing and auditing social media
Social Media
Governance
Social Media
Landscape
Strategy Planning
Social Media
Ethics
Compliance
Enterprise
Social Media
Marketing and
Communicatio
n
Relationship
Management
Legal Talent
Product and
Services
Information
Technology
Security and
Privacy
Monitoring
Social Media
Technology
Governance Strategy and Planning Ethics and Compliance Operations Technology and Infrastructure
Guiding
Principles
Economic
Conditions/
Industry Trends
Social Media
Strategy
Social Media
Investments
Code of Ethics
Compliance
Culture
Integration with
Business
Processes
Branding and
Reputation
Stakeholder
Engagement
Legal and
Regulatory
Compliance
Corporate Culture
Innovation,
Research and
Development
Architecture
Identity and
Access
Management
Social Media
Analytics
Content Sharing
(Videos,
Photos)
Board Structure
and Oversight
Geopolitical Policy
Digital Crisis
Management
Ethical
Culture/Personal
Ethics
Policies and
Procedures
Innovation and
Collaboration
Integrated
Marketing
Systems
Corporate
Service/Support
Litigation and
Dispute
Resolution
Employee Code
of Conduct
Crowd Sourcing
Employee
Dashboard and
User Interface
Virus and
Malware
Social Media
Trends
Monitoring
Social
Networking
Sites
Reputation and
Stakeholder
Relations
Laws and
Regulations
Web 2.0
Business Model
Change
Management
Monitoring and
Auditing
Compliance
Information
Management
Knowledge
Management
Social Media
Campaign/Online
Promotion
Customer/Partner
Feedback
Intellectual
Property
Talent
Recruitment and
Management
Concept
Testing/Product
Testing
Cloud
Computing
Social Media
Security
Employee
Monitoring
Blogs
Sustainability and
Climate Change
(S&CC)
Social Media
Platforms
Alliances/Joint
Ventures
Knowledge
Management
Reporting and
Prevention
Controls and
Monitoring
Training and
Development
using Social
Media
Buzz
Marketing/Viral
Campaigns
Community
Management
Copyright/
Trademark
Infringement
Social Media
Management
Team
Launch Mobile Devices
Information
Leakage
Content
Monitoring
Microblogging
Risk Oversight
and Supervision
Technological
Advances/
Changes
Outsourcing
Social Media
Program
Evaluation
Conflicts of
Interest
Cyber Law
Compliance
Internal
Communication
Influencer
Management
Performance
Management
Social Media
Tools
Privacy and Data
Protection
Influencer
Monitoring
Internet Forums
Competition
Program
Assessment and
Evaluation
Compliance
Reporting
Social Media
Agency
Response
Management
Employee
Productivity
Business
Continuity
Management
Social Media
Identity Theft
Wikis
Customer
Demands and
Trends
Technology
Adoption
Allegations &
Investigations
Content
Management
Conversations
Training on
Social Media
Change
Management
Security
Infrastructure
Location Based
Services (LBS)
Customers
Corporate
Actions and
Discipline
Media
Management
Trust/
Transparency
Employee
Relationships
Technology
Contracting,
Outsourcing and
Licensing
Influencer
Strategy
Training
Market Research
Workplace
Harassment/
Abuse
Ethics
Communication
Virtual
Workplace
E-Commerce/
Sales
Management
Social Media Risk Intelligence Map
Influencers
Supervision
Public Relations
e-Discovery
Social Media
Measurement
Social media risk intelligence map (RIM)
Provides breakdown of social media areas — Governance, Strategy and Planning,
Operations / Technology and identifies areas for which organization to focus on to help
mitigate risk from social media
Copyright © 2012 Deloitte Development LLC. All rights reserved.35 Assessing and auditing social media
Risk intelligence map sample
Risk class
Risk categories
Sub categories
Specific risks
Copyright © 2012 Deloitte Development LLC. All rights reserved.36 Assessing and auditing social media
Assessment Approach
Phase III: Design
and discovery
Phase II: Social
Listening
Phase IV: Assess
and analyze
Phase V:
Collaboration
and reporting
Phase I: Planning and
scoping
Activities:
• Identify key internal and
external stakeholders:
Marketing, Product
Development, IT,
Compliance, Legal,
Risk, etc.
• Obtain relevant
documents, strategy,
policies, governance
structure, etc.
• Define/agree on scope
and search criteria
• Identify areas of focus
• Develop a project plan
and time table including
program piloting
strategy
Activities:
• Define search terms:
brands, keywords,
topic points,
comparison
organizations
• Generate social media
research reports
through “listening” and
“risk sensing” tools
• Review raw data and
identify patterns,
anomalies, and areas
for additional focus
Activities:
• Obtain stakeholder feed
of “current state”
through:
– Online surveys
– Workshops
– Publicly available
or privately
subscribed
information
• Review existing social
media and relevant
security policies,
strategies, governance
• Review user access to
owned social sites
• Review regulatory
requirements
• Develop risk
assessment framework
Activities:
• Synthesize responses
• Aggregate the results
using broad themes
• Identify prioritized
emerging risks and
potential impacts from
assessment and
sensing research
• Validate the
observations with the
stakeholders in one on
one interviews
Activities:
• Collaborate with
Deloitte subject matter
experts and
management to stratify
emerging risks,
potential impact
• Develop risk mitigation
response strategies for
risks
• Identify
recommendations
based on insights
gained
• Summarize findings
Milestone:
• Project Plan
Milestone:
• Social media listening
report and high level
insights
Milestone:
• Questionnaires, surveys
or workshops
• Templates
Milestone:
• Summary of preliminary
findings
• Validation meetings
Deliverable:
• Final report on
recommendations and
findings
PhaseKeyActivitiesDeliverables
Lessons learned
Copyright © 2012 Deloitte Development LLC. All rights reserved.38 Assessing and auditing social media
• Social governance
– Cross functional vs. Limited, decentralized
• Training and awareness/policies
– Personal vs. Business use
• Social business strategy
– Center of excellence
• Regulatory compliance
– Bloggers receive payment in kind
• Entitlement reviews
– External process
• Data leakage protection / monitoring
– Internal vs. External
Lessons learned from recent assessments
Auditing social media
Copyright © 2012 Deloitte Development LLC. All rights reserved.40 Assessing and auditing social media
• Does the policy specify the approved
social media channels? Who has access
to these accounts and who maintains
them?
• Does the policy address intellectual
property rights?
• Does the policy require monitoring of all
content posted on social media sites?
• Does the policy give a careful
consideration to review and accept the
social media provider’s terms of service?
• Does the policy specify whether only
public information can be posted on
social media websites?
Social media policy
• Does the policy specify what the
employees can and cannot do on a social
network?
• Can employees communicate on behalf
of the Company?
• Does the social media policy connect with
other policies that might be affected by
social media (including IT, Ethics, IP,
Privacy, Anti-discrimination, harassment,
etc.)?
• Does the policy specify required training?
• Does the policy specify what is
monitored?
• Does the policy clarify consequences?
Business Use Employees’ Use
+
Copyright © 2012 Deloitte Development LLC. All rights reserved.41 Assessing and auditing social media
Awareness program
ISACA recommends any strategy to address the risks of social media usage should first
focus on user behavior through the development of policies and supporting training and
awareness program that covers:
• Whether it is allowed
• The nondisclosure/posting of business-related content
• The discussion of workplace-related topics
• Inappropriate sites, content or conversations
Personal use in the
workplace
Personal use
outside the
workplace
Business use
• Whether it is allowed
• The nondisclosure/posting of business-related content
• The discussion of workplace-related topics
• Inappropriate sites, content or conversations
• Whether it is allowed, and process to gain approval for use
• The scope of topics or information permitted to flow through
this channel
• Disallowed activities
• The escalation process for customer issues
Copyright © 2012 Deloitte Development LLC. All rights reserved.42 Assessing and auditing social media
Source: ISACA, Social Media: Business Benefits and Security, Governance and Assurance Perspectives [Whitepaper].
People
• Have effective trainings been delivered to all users?
• Do users (including employees) receive regular awareness
communications regarding policies and risks?
Process/Data
• Have business processes that utilize social media been reviewed to
determine that they are aligned with policies and standards of the
enterprise?
• Are content control processes in place to determine that social
communications intended to represent the company are approved
before dissemination?
Technology
• Does IT have a strategy and the supporting capabilities to manage
technical risks presented by social media?
• Do technical controls and processes adequately support social media
policies and standards?
• Does the enterprise have an established process to address the risk of
unauthorized/fraudulent use of its brand on social media sites?
Focus areas
Copyright © 2012 Deloitte Development LLC. All rights reserved.43 Assessing and auditing social media
Auditing social media — people
Loss of productivity
Identity theft
Social engineering
Risk Example Controls
Objective:
Employees, contractors and customers are
aware of their responsibilities relating to social
media.
Activities:
• Establish user agreements for social media
use
• Conduct awareness training to inform users
of the risks involved using social media
websites
• Use content-filtering technology such as
DLP (Data Loss Prevention)
• Limit access to social media sites
Responsible parties:
HR, Information Security
HR policy violations
Copyright © 2012 Deloitte Development LLC. All rights reserved.44 Assessing and auditing social media
Auditing social media — process
Reputational loss
Regulatory compliance risk
(i.e. copyright, trademark infringement, and privacy issues)
False impression
Risk Example Controls
Objective:
The enterprise brand is protected from
negative publicity or regulation violation
Activities:
• Establish policies to determine legal-
sensitive communications are tracked and
archived
• Conduct awareness training to inform users
of the risks involved using social media
websites
• Scan the internet for misuse of the
enterprise brand
Responsible parties:
HR, Information Security
Copyright © 2012 Deloitte Development LLC. All rights reserved.45 Assessing and auditing social media
Auditing social media — data
Unauthorized disclosure
Improper content
Intellectual property leakage
Risk Example Controls
Objective:
Enterprise information is protected from
unauthorized access or leakage through/by
social media.
Activities:
• Establish user agreements for social media
sites
• Develop policies on the use of enterprise-
wide intellectual property
• Determine if there is a capability to log the
communications
Responsible parties:
Legal, HR, Information Security
Copyright © 2012 Deloitte Development LLC. All rights reserved.46 Assessing and auditing social media
Auditing social media — technology
Constraining network bandwidth
Virus/Worms via the social media sites
Data theft from mobile devices
Risk Example Controls
Objective:
IT infrastructure supports risks introduced by
social media.
Activities:
• Install anti-virus applications on all systems
including mobile devices
• Use content-filtering technology such as
DLP
• Limit access to social media sites during
business hours
Responsible parties:
Information Security
Copyright © 2012 Deloitte Development LLC. All rights reserved.47 Assessing and auditing social media
• Perform a study on what organization specific foot printing information is available on the
Internet, and how it might be used to produce an exploit that targets the organization’s IT
or Industrial Systems.
The below assessments could be performed to in conjunction with a social media
assessment to address other vulnerabilities, that could be related social media.
Cyber threat profile analysis
Suspicious program diagnostics
• Use available industry hash data sets and cyber intelligence to match against a generated
inventory of system files endeavoring to identify hidden exploits. Perform digital forensic
analysis on suspect computers including examining system memory.
Intranet cyber compromise diagnostic
• Security event logs and infrastructure logs are analyzed to look for evidence of internal
machines that may have been compromised and are attempting to communicate with
miscreant controlled devices on the Internet.
Anti-phishing capability diagnostic
• Assess organizations’ anti-phishing program in order to help identify gaps and
improvement opportunities. It includes looking at recent phishing incidents, intelligence
services, and the organization’s incident handling procedures.
Additional considerations
Group exercise
Copyright © 2012 Deloitte Development LLC. All rights reserved.49 Assessing and auditing social media
Group Topic Discuss at your table Share with the group
Group 1 Governance and
strategy
• How is the area relevant to your
organization?
• Top three risks
• Current Challenges
• How you are addressing
risks and challenges
• Share other observations
Group 2 Legal and regulatory
compliance
• What are key risks in
this area?
Group 3 Security and privacy • What are the controls that you are
seeing to address these risks?
Group 4 Brand and reputation
management
• Given the above, any interesting
trends emerging?
Working session
Questions?
Copyright © 2012 Deloitte Development LLC. All rights reserved.51 Assessing and auditing social media
Khalid Wasti
Director
Deloitte & Touche LLP
(212) 436-5156
kwasti@deloitte.com
Contact info
Copyright © 2012 Deloitte Development LLC. All rights reserved.52 Assessing and auditing social media
• “Web 2.0 reinvents corporate networking.” Gopal, Raj, et al. Deloitte Consulting LLP
• “Market Intelligence and Content Curating.” Eric Openshaw, Deloitte & Touche LLP
• “Social Media Audit/Assurance Program” ISACA
• “Social Media: Business Benefits and Security, Governance and Assurance Perspective” ISACA
• “2012 Identity Fraud Report: Social Media and Mobile Forming the New Fraud Frontier”
Javelin Strategy & Research
• “Auditing Social Media: A Governance and Risk Guide” by Peter R. Scott and J. Mike Jacka
• Statistics Brain: Social Network Statistics, www.statisticbrain.com/social-networking-statistics
• Internal Auditor, “The Social Media Scene”, August 2012, Allison Cain
References and additional resources
About Deloitte
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of
member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed
description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Please see www.deloitte.com/us/about
for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest
clients under the rules and regulations of public accounting.
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Member of Deloitte Touche Tohmatsu Limited

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Social media-assessment

  • 3. Copyright © 2012 Deloitte Development LLC. All rights reserved.2 Assessing and auditing social media Overview of social media Social media opportunities Social media risks Regulatory environment A risk intelligent approach Contents
  • 5. Copyright © 2012 Deloitte Development LLC. All rights reserved.4 Assessing and auditing social media Wikipedia: “Social media includes web- and mobile-based technologies to support interactive dialogue and introduce substantial and pervasive changes to communication between organizations, communities, and individuals. Social media are social software which mediate human communication.” Source: Wikipedia, Social Media, November 12, 2012, http://en.wikipedia.org/wiki/Social_media Merriam Webster: “Social media are forms of electronic communication (as Web sites for social networking and microblogging) through which users create online communities to share information, ideas, personal messages, and other content (as videos).” Source: Merriam Webster, November 12, 2012, http://en.wikipedia.org/wiki/Social_media About.com “Social media is a type of online media that expedites conversation as opposed to traditional media, which delivers content but does not allow readers/viewers/listeners to participate in the creation or development of the content.” Source: Social Media Definition, Susan Ward, November 12, 2012, http://sbinfocanada.about.com/od/socialmedia/g/socialmedia.htm Social media is continuing to evolve and so the definition is also changing. Here are some of the recent definitions. Social media definition
  • 6. Copyright © 2012 Deloitte Development LLC. All rights reserved.5 Assessing and auditing social media Social media Description Collaboration A page or site designed to enable collaborative contribution and modification of content by users Web Log Communications (Blogs) Frequent online publications with commentary on current events, subjects, or one’s personal thoughts Social Networking Site focused on building online communities, establishing connections, and providing avenues for social interaction Presence and Microblogging Brief real-time updates of personal commentary, news, or status (aka “Tweets”) Micro-Media: Online photo and video sharing Media-centric online communities that facilitate the viewing, sharing, and “tagging,” or classification, of media content Online Review & Opinion Forums Websites/Tools that allow users to search for peer reviews or advice on a product or service, as well as to contribute their own ratings and comments Social Networking Location Based Forums Website applications that allow users to “check in” and locate friends in various locations, share reviews and earn rewards Entertainment Social network games or interactive video games Social media is an umbrella term for a host of sites and technology that facilitates social interaction, sharing, and creation of user-generated content, and aggregation of users’ opinions and recommendations. Common forms of social media Social media landscape — Popular examples
  • 7. Copyright © 2012 Deloitte Development LLC. All rights reserved.6 Assessing and auditing social media Social Media Includes:
  • 8. Copyright © 2012 Deloitte Development LLC. All rights reserved.7 Assessing and auditing social media 680,747 views per corporate YouTube channel Facts and figures > 40% of social media users access content from their mobile phone 8 out of 10 companies are talked about on Twitter What happens in Vegas stays in Social Media 2 2nd largest search engine in the world is YouTube 78 78% of consumers trust opinions of others > 62% of Fortune 500 Companies have an active corporate Facebook or Twitter account 10.5 Billion Minutes are spent on Facebook each day excluding mobile 1 No. 1 Web activity is Social Media 80% of companies use social media for recruiting > 1 Billion active Facebook users 2.9 Billion Hours are spent on YouTube each month 190 190 Million tweets per day Sources: Statistics Brain: Social Network Statistics, www.statisticbrain.com/social-networking-statistics Social Media Revolution 2012, The Total Profit, October 23, 2011, http://www.youtube.com/watch?v=0eUeL3n7fDs
  • 10. Copyright © 2012 Deloitte Development LLC. All rights reserved.9 Assessing and auditing social media Opportunities Build a brand • Ability to build trust and engage customers through direct communication channels • Opportunity to grow through increased awareness of the brand • Better understanding of customer sentiment of the brand • Ability to proactively monitor and address issues early that surface on social sites • Customer feedback / dissatisfaction • Negative press • Ability for greater favorable perceptions of the brand • Ratings / Reviews • Ability to detect early warning signs of potential product or service issues Marketing • Increased marketing channels and opportunities • Increased brand awareness among target customers • Ability to engage in dialogue directly with customers • Ability to increase traffic to website • Improved insights about target market • Ability to identify new product or service opportunities • Ability to quickly reach the masses at a lower cost than traditional marketing and advertising Employees • Opportunity to improve operational efficiencies and increase the productivity of employees through collaboration • Ability to attract and retain talent Social media: Opportunities
  • 11. Copyright © 2012 Deloitte Development LLC. All rights reserved.10 Assessing and auditing social media Social media Generate Prospects and Leads (Sales) 1 • Decrease time to market for new products • Increase marketing effectiveness • Develop new revenue opportunities • Leverage “interest” based marketing & advertising Decrease Costs 2 • Decrease R&D costs for new products by listening to your customers (and prospects) • Focus on inexpensive social media tools instead of using the traditional expensive marketing channels • Decrease customer support costs Increase Loyalty 3 • Increase customer insights and intelligence (“Voice of Customer”) • Improve customer experience responsiveness • Improve customer education, expertise and service • Direct contact with the customer instead of indirect through the retail channels Manage Brand Reputation 4 • Increase brand awareness through social media • Protect brand and manage reputation • Benefit from spontaneous reactions from the community by connecting like-minded peers Loss of Control 1 • The voice of the customer is amplified • Companies no longer control the message or topic • Messages might include negative publicity Inconsistent message 2 • When engaging several employees in the social media world, their messages and responses may not be consistent and aligned with the strategy of the company Confidential Information 3 • The use of social media sites enables users to circumvent company controls, opening up the potential to violate communication policies • Education and training for employees is a component to managing loss of information Productivity loss 4 • Social media drives collaboration among co- workers but can also be a major distraction in the work place Benefits Challenges
  • 13. Copyright © 2012 Deloitte Development LLC. All rights reserved.12 Assessing and auditing social media Social media: Risks Anticipated risks Legal and regulatory compliance • Disclosure of confidential data (e.g., Personal Health Information, Personally Identifiable Information) • Violation of copyright laws • Protection of intellectual property rights, patents, and trademarks • Regulatory noncompliance Security and privacy • Identity theft and social engineering • Technical exploits: Malware, viruses/worms, Flash vulnerabilities, and XML injection • Insufficient monitoring capabilities • Data leakage Brand and reputation damage • Viral video or bad press resulting from a security incident (i.e., loss of data) • Defamation, unfavorable or untrue posts • Copyright infringement • Insufficient monitoring and listening capabilities Social governance and strategy • Lack of policy • Lack of risk oversight • Misalignment of social strategy with strategic vision Employees • Inappropriate use of social media • Distraction/productivity loss • Inadequate training and awareness
  • 14. Copyright © 2012 Deloitte Development LLC. All rights reserved.13 Assessing and auditing social media Social media risk landscape Organization People Technology Data Unauthorized Disclosure Intellectual Property leakage Vulnerabilities Identity Theft Brand / Reputation Loss Public Unsatisfied Constituents Impact network availability (DOS) Virus/ Worms/Trojans Loss of Productivity HR Policy Violations Social Engineering / Impersonation Privacy Risk Trademark Infringement Loss of Control Over Content Copyright Issue Lack of Situational Awareness Negative Publicity False Impression/ Misguidance
  • 16. Copyright © 2012 Deloitte Development LLC. All rights reserved.15 Assessing and auditing social media Regulatory Notice 10–06, 11–39: Guidance on blogs, social networking websites, and business communications The goal of the notice is to ensure: • Investors are protected from false or misleading claims and representations • Firms are able to effectively and appropriately supervise their associated persons’ participation in social sites Financial Industry Regulatory Authority (FINRA) Sources: FINRA Regulatory Notice 10-06: Social Media Web Sites: Guidance on Blogs and Social Networking Web Sites, January 2010 FINRA Regulatory Notice 11-39: Social Media Websites and the Use of Personal Devices for Business Communications : Guidance on Social Networking Websites and Business Communications, August 2011
  • 17. Copyright © 2012 Deloitte Development LLC. All rights reserved.16 Assessing and auditing social media Recordkeeping • Firms are required to retain records of communications for 3 years related to the broker-dealer’s business that are made through social media sites • Originals of all communications received and copies of all communications sent by the member, broker or dealer • Receipt of each compliant must be acknowledged within 15 business days Suitability • Broker-dealers are required to determine that recommendations are suitable for every investor to whom it is made Supervision • Maintain and establish mechanisms to supervise activities of associated persons to achieve compliance • Registered principal must review and approve social media sites and content to be posted (e.g., blogs and social networking sites) • Associated persons / registered representatives must be trained and not present undue risk • Policies and procedures are required FINRA (cont.)
  • 18. Copyright © 2012 Deloitte Development LLC. All rights reserved.17 Assessing and auditing social media Third-party posts • Customer and third-party posts on social sites established by the firm are not considered the firm’s communication • Exceptions – The firm aided in preparation of the content – The firm endorses or approves the content FINRA (cont.)
  • 19. Copyright © 2012 Deloitte Development LLC. All rights reserved.18 Assessing and auditing social media Memorandum OM 12–31 from the Office of General Counsel of NLRB emphasized that employee rights under Section 7 of the National Labor Relations Act (NLRA) must be considered when creating a social media policy or disciplining an employee for social networking activity. At issue is whether social media policies violate employees’ right, under Section 7 of the NLRA, to communicate or work together in “concerted activities” for the purpose of collective bargaining or to improve working conditions and terms of employment. Employers in both union and nonunion workplaces who terminate or discipline an employee based on a social media posting that the NLRB finds to be “protected concerted activity” — such as a Facebook conversation among employees complaining about pay — may be violating Section 7. “The Employer’s rule prohibited “making disparaging comments about the company through any media, including online blogs, other electronic media or through the media.” “We concluded that this rule was unlawful because it would reasonably be construed to restrict Section 7 activity…” National Labor Relations Board (NLRB) Sources: National Labor Relations Act, Rights of Employees, Sec. 7. [§ 157.], National Labor Relations Board Operations Management Memorandum 12-31, Office of General Counsel of National Labor Relations Board, January 24, 2012
  • 20. Copyright © 2012 Deloitte Development LLC. All rights reserved.19 Assessing and auditing social media FTC 16 CFR Part 255 “Guides Concerning the Use of Endorsements and Testimonials in Advertising” • Guides address the application of Section 5 of the FTC Act (15 U.S.C. 45) regarding endorsements and testimonials in advertising • The guides provide the basis for voluntary compliance with the law by advertisers and endorsers • Inconsistent practices with these guides may result in corrective action by the commission Federal Trade Commission (FTC) Source: Federal Trade Commission, 16 CFR Part 255, Guides Concerning the Use of Endorsements and Testimonials in Advertising, Federal Trade Commission, Final Rule; Notice of adoption of revised Guides, October 2009
  • 21. Copyright © 2012 Deloitte Development LLC. All rights reserved.20 Assessing and auditing social media FTC 16 CFR Part 255 “Guides Concerning the Use of Endorsements and Testimonials in Advertising” • Endorsements must reflect the honest opinions, findings, beliefs, or experience of the endorser and may not be deceptive – Both advertisers and endorsers can be liable for endorser’s statements • Section 5 requires the disclosure of a connection between an advertiser and an endorser when the relationship is not apparent within the communication containing the endorsement. – For example, an advertiser’s provision of a gift to a blogger for posting blog content could constitute a material connection that is not reasonably expected by readers of the blog. Federal Trade Commission (FTC) (cont.)
  • 22. Copyright © 2012 Deloitte Development LLC. All rights reserved.21 Assessing and auditing social media National Examination Alert with investment adviser considerations for evaluating use of social media compliance policies: • Usage guidelines • Monitoring • Content standards • Information security Details can be found at www.sec.gov U.S. Securities and Exchange Commission (SEC)
  • 23. Copyright © 2012 Deloitte Development LLC. All rights reserved.22 Assessing and auditing social media Federal Financial Institutions Examination Council (FFIEC) Social Media: Consumer Compliance Risk Management Guidance • Financial institutions should have a risk management program commensurate with the breadth of the financial institution’s involvement in social media, that allows it to identify, measure, monitor, and control the risks related to this medium. • Institutions are to control content on their social media site owned or administered by a third party and to change policies regarding information provided through the site. • Financial institutions should have procedures to address risks from occurrences such as members of the public posting confidential or sensitive information. • Financial institutions’ incident response protocol regarding a security event, such as a data breach or account takeover, should include social media, as appropriate.
  • 24. A risk intelligent approach
  • 25. Copyright © 2012 Deloitte Development LLC. All rights reserved.24 Assessing and auditing social media Assessment Approach Phase III: Design and discovery Phase II: Social Listening Phase IV: Assess and analyze Phase V: Collaboration and reporting Phase I: Planning and scoping Activities: • Identify key internal and external stakeholders: Marketing, Product Development, IT, Compliance, Legal, Risk, etc. • Obtain relevant documents, strategy, policies, governance structure, etc. • Define/agree on scope and search criteria • Identify areas of focus • Develop a project plan and time table including program piloting strategy Activities: • Define search terms: brands, keywords, topic points, comparison organizations • Generate social media research reports through “listening” and “risk sensing” tools • Review raw data and identify patterns, anomalies, and areas for additional focus Activities: • Obtain stakeholder feed of “current state” through: – Online surveys – Workshops – Publicly available or privately subscribed information • Review existing social media and relevant security policies, strategies, governance • Review user access to owned social sites • Review regulatory requirements • Develop risk assessment framework Activities: • Synthesize responses • Aggregate the results using broad themes • Identify prioritized emerging risks and potential impacts from assessment and sensing research • Validate the observations with the stakeholders in one on one interviews Activities: • Collaborate with Deloitte subject matter experts and management to stratify emerging risks, potential impact • Develop risk mitigation response strategies for risks • Identify recommendations based on insights gained • Summarize findings Milestone: • Project Plan Milestone: • Social media listening report and high level insights Milestone: • Questionnaires, surveys or workshops • Templates Milestone: • Summary of preliminary findings • Validation meetings Deliverable: • Final report on recommendations and findings PhaseKeyActivitiesDeliverables
  • 26. Copyright © 2012 Deloitte Development LLC. All rights reserved.25 Assessing and auditing social media Understanding the social media perspective of the organization The perspectives below generalize the social media interactions of an organization. It is important to understand the social media perspective before assessing risk. Organization — Internal • Hosted on organization-owned or controlled technology • Restricted to organization employees only (in some special cases to clients and vendors) Organization — Public • Hosted on organization-owned technology (like a CEO blog on organization’s website) or is hosted by an external provider on their technology • Open to public • Sponsored by the organization or one of its business units in accordance with the organization policy Public • Hosted by an external provider on their technology • Open to public • Not sponsored by the organization Key Risk considerations Reputation risk management Legal and regulatory compliance Security and privacy Governance and strategy Training and awareness
  • 27. Copyright © 2012 Deloitte Development LLC. All rights reserved.26 Assessing and auditing social media • Who in the organization is responsible for social media: Marketing, Legal, IT, HR, Public Relations, etc. • Is there a social media center of excellence? • In what social media channels does the organization have an active presence? • Has a risk assessment been conducted to identify risks associated with the current use of social media? • Is there an established policy (and supporting standards) that addresses social media use? • Does the policy address all aspects of social media use in the workplace — both business and personal? • Have employees been educated on appropriate use of social media and are they aware of the policy? • Do employees receive periodic awareness communication regarding policies and risks? • What technology safeguards are in place? • Is there risk management oversight of policies and procedures? • Does a social strategy exist? Understand the social media landscape of the organization Source: Social Media: Business Benefits and Security, Governance and Assurance Perspectives, ISACA, 2010
  • 28. Copyright © 2012 Deloitte Development LLC. All rights reserved.27 Assessing and auditing social media Include key areas within the environment and identify stakeholders Social media activity affects a wide range of business functions within an organization. An effective social media risk assessment should include key areas affected by the use of social media and the identification of key stakeholders within those areas who understand the processes and pain points. Assess the environment Conduct interviews (or use questionnaires) with key stakeholders to asses current social media practices and uncover the associated risks with: • Reputation management • Governance and strategy • Legal and regulatory compliance • Security and privacy • Training and awareness Validate risks Summarize, socialize and agree on risks Prioritize, develop mitigation strategies and roadmap Conduct facilitated workshops to rank risks, develop recommendations, prioritize and build a roadmap Risk assessment approach • Marketing • Public relations • Customer service • Communications • Human resources • Internal audit • Information technology • Security • Legal & compliance • Risk • Crisis management • Other
  • 29. Copyright © 2012 Deloitte Development LLC. All rights reserved.28 Assessing and auditing social media Assessment Approach Phase III: Design and discovery Phase II: Social Listening Phase IV: Assess and analyze Phase V: Collaboration and reporting Phase I: Planning and scoping Activities: • Identify key internal and external stakeholders: Marketing, Product Development, IT, Compliance, Legal, Risk, etc. • Obtain relevant documents, strategy, policies, governance structure, etc. • Define/agree on scope and search criteria • Identify areas of focus • Develop a project plan and time table including program piloting strategy Activities: • Define search terms: brands, keywords, topic points, comparison organizations • Generate social media research reports through “listening” and “risk sensing” tools • Review raw data and identify patterns, anomalies, and areas for additional focus Activities: • Obtain stakeholder feed of “current state” through: – Online surveys – Workshops – Publicly available or privately subscribed information • Review existing social media and relevant security policies, strategies, governance • Review user access to owned social sites • Review regulatory requirements • Develop risk assessment framework Activities: • Synthesize responses • Aggregate the results using broad themes • Identify prioritized emerging risks and potential impacts from assessment and sensing research • Validate the observations with the stakeholders in one on one interviews Activities: • Collaborate with Deloitte subject matter experts and management to stratify emerging risks, potential impact • Develop risk mitigation response strategies for risks • Identify recommendations based on insights gained • Summarize findings Milestone: • Project Plan Milestone: • Social media listening report and high level insights Milestone: • Questionnaires, surveys or workshops • Templates Milestone: • Summary of preliminary findings • Validation meetings Deliverable: • Final report on recommendations and findings PhaseKeyActivitiesDeliverables
  • 30. Copyright © 2012 Deloitte Development LLC. All rights reserved.29 Assessing and auditing social media Approach Period data was gathered [tbd] Research Hypothesis Tool Selection Gather Raw Data Insights Investigate •Company Name •Competitors •Keywords •Industry •Ask Questions •Look for information •Seek sources •Speculate •Formulate •Radian6 •PeopleBrowsr •Attensity360 •Mutual Mind •Webtrends •Google Analytics •Google Trends •Twitalizer •PeerIndex •Klout •Kred •Mantis Pulse •WiseWindow •Adobe Social •Bottlenose •DataSift •Gnip •Alterian SM2 •Numbers •Charts •Graphs •Lists •Pictures •People •Interesting Patterns •Anomalies •Why? •Results match business goals? •Outside factors •What can be influenced? • Best ROI • Fastest • Easiest • Most important • Most critical • Most strategic More Research •Deeper Dive •New Questions •Follow on answers
  • 31. Copyright © 2012 Deloitte Development LLC. All rights reserved.30 Assessing and auditing social media Potential opportunities Community Management § Tend to the social garden by facilitating conversations between customers, employees, and partners § Assign Community Lead to manage and set strategic direction for Customer Communities across platforms § Analyze community data to enhance business strategy and product development § Regularly monitor and push appropriate content to Customer & Partner Communities Do these resonate? What other focus areas are most impactful to you? Proactive Social Support § Joining social conversations to help inform customers § Enabling tools & resources to monitor social platforms for support related events § Monitoring, Analyze, & Address support related conversations § Dedicate a percentage of support staff time to mining social channels for additional support related events Voice of Competitor’s Customers § Know what competitors’ products customers are purchasing and understand customer purchasing drivers § Configure listening tool to route these to sales and marketing for conversions and campaigns § Integrate CRM system with social listening to create competitor customer profiles § Identify competitor crises and establish war room procedures to quickly act on competitive advantages. Social Media Command Center § Set up a Command Center to monitor and respond to social trends, opportunities, and crisis. § Evaluate and select social monitoring, routing and interaction platforms § Formulate organization response policies to social crisis and events § Train resources for rotational assignment to social command and response teams
  • 32. Copyright © 2012 Deloitte Development LLC. All rights reserved.31 Assessing and auditing social media Assessment Approach Phase III: Design and discovery Phase II: Social Listening Phase IV: Assess and analyze Phase V: Collaboration and reporting Phase I: Planning and scoping Activities: • Identify key internal and external stakeholders: Marketing, Product Development, IT, Compliance, Legal, Risk, etc. • Obtain relevant documents, strategy, policies, governance structure, etc. • Define/agree on scope and search criteria • Identify areas of focus • Develop a project plan and time table including program piloting strategy Activities: • Define search terms: brands, keywords, topic points, comparison organizations • Generate social media research reports through “listening” and “risk sensing” tools • Review raw data and identify patterns, anomalies, and areas for additional focus Activities: • Obtain stakeholder feed of “current state” through: – Online surveys – Workshops – Publicly available or privately subscribed information • Review existing social media and relevant security policies, strategies, governance • Review user access to owned social sites • Review regulatory requirements • Develop risk assessment framework Activities: • Synthesize responses • Aggregate the results using broad themes • Identify prioritized emerging risks and potential impacts from assessment and sensing research • Validate the observations with the stakeholders in one on one interviews Activities: • Collaborate with Deloitte subject matter experts and management to stratify emerging risks, potential impact • Develop risk mitigation response strategies for risks • Identify recommendations based on insights gained • Summarize findings Milestone: • Project Plan Milestone: • Social media listening report and high level insights Milestone: • Questionnaires, surveys or workshops • Templates Milestone: • Summary of preliminary findings • Validation meetings Deliverable: • Final report on recommendations and findings PhaseKeyActivitiesDeliverables
  • 33. Copyright © 2012 Deloitte Development LLC. All rights reserved.32 Assessing and auditing social media Reputation risk management • Is there an effective crisis management plan for the escalation of incidents? • Is customer service involved and are they trained on crisis management? Legal and regulatory compliance • What is the landscape of the regulatory environment impacting the organization (e.g., FINRA, NRLB, FTC, HIPAA ) • Does the policy support the regulatory landscape and do social media operations comply with the internal policy, legal and regulatory requirements? • Is the organization’s use of social media in compliance with social media site policies? Security and privacy • Are the security and privacy risks associated with the adoption of social media being addressed? • What safeguards are in place to prevent data leakage? • Are cyber security safeguards in place to detect and prevent threats from social engineering attacks (e.g., phishing, identify theft)? Key assessment considerations Key Risk considerations Reputation risk management Legal and regulatory compliance Security and privacy Governance and strategy Training and awareness
  • 34. Copyright © 2012 Deloitte Development LLC. All rights reserved.33 Assessing and auditing social media Governance and strategy • Is there a well-defined and documented strategy? • Has a cross-functional governance framework been adopted that includes oversight of policies and adoption of initiatives? • Is there a policy? (Business versus Personal use) – If one exists, what’s in it? • Channels where the organization participates • Who is authorized to speak on behalf of the organization • Processes and tools in place to monitor communications by employees, customers or the public • Links to other related policies (e.g., acceptable use, handling sensitive data, data retention) • Restrictions • Consequences for noncompliance – Do employees know about it? Training and Awareness • What type of training and education is in place? • What is the frequency and timing? • Has an awareness program been adopted? Key assessment considerations (cont.) Key Risk considerations Reputation risk management Legal and regulatory compliance Security and privacy Governance and strategy Training and awareness
  • 35. Copyright © 2012 Deloitte Development LLC. All rights reserved.34 Assessing and auditing social media Social Media Governance Social Media Landscape Strategy Planning Social Media Ethics Compliance Enterprise Social Media Marketing and Communicatio n Relationship Management Legal Talent Product and Services Information Technology Security and Privacy Monitoring Social Media Technology Governance Strategy and Planning Ethics and Compliance Operations Technology and Infrastructure Guiding Principles Economic Conditions/ Industry Trends Social Media Strategy Social Media Investments Code of Ethics Compliance Culture Integration with Business Processes Branding and Reputation Stakeholder Engagement Legal and Regulatory Compliance Corporate Culture Innovation, Research and Development Architecture Identity and Access Management Social Media Analytics Content Sharing (Videos, Photos) Board Structure and Oversight Geopolitical Policy Digital Crisis Management Ethical Culture/Personal Ethics Policies and Procedures Innovation and Collaboration Integrated Marketing Systems Corporate Service/Support Litigation and Dispute Resolution Employee Code of Conduct Crowd Sourcing Employee Dashboard and User Interface Virus and Malware Social Media Trends Monitoring Social Networking Sites Reputation and Stakeholder Relations Laws and Regulations Web 2.0 Business Model Change Management Monitoring and Auditing Compliance Information Management Knowledge Management Social Media Campaign/Online Promotion Customer/Partner Feedback Intellectual Property Talent Recruitment and Management Concept Testing/Product Testing Cloud Computing Social Media Security Employee Monitoring Blogs Sustainability and Climate Change (S&CC) Social Media Platforms Alliances/Joint Ventures Knowledge Management Reporting and Prevention Controls and Monitoring Training and Development using Social Media Buzz Marketing/Viral Campaigns Community Management Copyright/ Trademark Infringement Social Media Management Team Launch Mobile Devices Information Leakage Content Monitoring Microblogging Risk Oversight and Supervision Technological Advances/ Changes Outsourcing Social Media Program Evaluation Conflicts of Interest Cyber Law Compliance Internal Communication Influencer Management Performance Management Social Media Tools Privacy and Data Protection Influencer Monitoring Internet Forums Competition Program Assessment and Evaluation Compliance Reporting Social Media Agency Response Management Employee Productivity Business Continuity Management Social Media Identity Theft Wikis Customer Demands and Trends Technology Adoption Allegations & Investigations Content Management Conversations Training on Social Media Change Management Security Infrastructure Location Based Services (LBS) Customers Corporate Actions and Discipline Media Management Trust/ Transparency Employee Relationships Technology Contracting, Outsourcing and Licensing Influencer Strategy Training Market Research Workplace Harassment/ Abuse Ethics Communication Virtual Workplace E-Commerce/ Sales Management Social Media Risk Intelligence Map Influencers Supervision Public Relations e-Discovery Social Media Measurement Social media risk intelligence map (RIM) Provides breakdown of social media areas — Governance, Strategy and Planning, Operations / Technology and identifies areas for which organization to focus on to help mitigate risk from social media
  • 36. Copyright © 2012 Deloitte Development LLC. All rights reserved.35 Assessing and auditing social media Risk intelligence map sample Risk class Risk categories Sub categories Specific risks
  • 37. Copyright © 2012 Deloitte Development LLC. All rights reserved.36 Assessing and auditing social media Assessment Approach Phase III: Design and discovery Phase II: Social Listening Phase IV: Assess and analyze Phase V: Collaboration and reporting Phase I: Planning and scoping Activities: • Identify key internal and external stakeholders: Marketing, Product Development, IT, Compliance, Legal, Risk, etc. • Obtain relevant documents, strategy, policies, governance structure, etc. • Define/agree on scope and search criteria • Identify areas of focus • Develop a project plan and time table including program piloting strategy Activities: • Define search terms: brands, keywords, topic points, comparison organizations • Generate social media research reports through “listening” and “risk sensing” tools • Review raw data and identify patterns, anomalies, and areas for additional focus Activities: • Obtain stakeholder feed of “current state” through: – Online surveys – Workshops – Publicly available or privately subscribed information • Review existing social media and relevant security policies, strategies, governance • Review user access to owned social sites • Review regulatory requirements • Develop risk assessment framework Activities: • Synthesize responses • Aggregate the results using broad themes • Identify prioritized emerging risks and potential impacts from assessment and sensing research • Validate the observations with the stakeholders in one on one interviews Activities: • Collaborate with Deloitte subject matter experts and management to stratify emerging risks, potential impact • Develop risk mitigation response strategies for risks • Identify recommendations based on insights gained • Summarize findings Milestone: • Project Plan Milestone: • Social media listening report and high level insights Milestone: • Questionnaires, surveys or workshops • Templates Milestone: • Summary of preliminary findings • Validation meetings Deliverable: • Final report on recommendations and findings PhaseKeyActivitiesDeliverables
  • 39. Copyright © 2012 Deloitte Development LLC. All rights reserved.38 Assessing and auditing social media • Social governance – Cross functional vs. Limited, decentralized • Training and awareness/policies – Personal vs. Business use • Social business strategy – Center of excellence • Regulatory compliance – Bloggers receive payment in kind • Entitlement reviews – External process • Data leakage protection / monitoring – Internal vs. External Lessons learned from recent assessments
  • 41. Copyright © 2012 Deloitte Development LLC. All rights reserved.40 Assessing and auditing social media • Does the policy specify the approved social media channels? Who has access to these accounts and who maintains them? • Does the policy address intellectual property rights? • Does the policy require monitoring of all content posted on social media sites? • Does the policy give a careful consideration to review and accept the social media provider’s terms of service? • Does the policy specify whether only public information can be posted on social media websites? Social media policy • Does the policy specify what the employees can and cannot do on a social network? • Can employees communicate on behalf of the Company? • Does the social media policy connect with other policies that might be affected by social media (including IT, Ethics, IP, Privacy, Anti-discrimination, harassment, etc.)? • Does the policy specify required training? • Does the policy specify what is monitored? • Does the policy clarify consequences? Business Use Employees’ Use +
  • 42. Copyright © 2012 Deloitte Development LLC. All rights reserved.41 Assessing and auditing social media Awareness program ISACA recommends any strategy to address the risks of social media usage should first focus on user behavior through the development of policies and supporting training and awareness program that covers: • Whether it is allowed • The nondisclosure/posting of business-related content • The discussion of workplace-related topics • Inappropriate sites, content or conversations Personal use in the workplace Personal use outside the workplace Business use • Whether it is allowed • The nondisclosure/posting of business-related content • The discussion of workplace-related topics • Inappropriate sites, content or conversations • Whether it is allowed, and process to gain approval for use • The scope of topics or information permitted to flow through this channel • Disallowed activities • The escalation process for customer issues
  • 43. Copyright © 2012 Deloitte Development LLC. All rights reserved.42 Assessing and auditing social media Source: ISACA, Social Media: Business Benefits and Security, Governance and Assurance Perspectives [Whitepaper]. People • Have effective trainings been delivered to all users? • Do users (including employees) receive regular awareness communications regarding policies and risks? Process/Data • Have business processes that utilize social media been reviewed to determine that they are aligned with policies and standards of the enterprise? • Are content control processes in place to determine that social communications intended to represent the company are approved before dissemination? Technology • Does IT have a strategy and the supporting capabilities to manage technical risks presented by social media? • Do technical controls and processes adequately support social media policies and standards? • Does the enterprise have an established process to address the risk of unauthorized/fraudulent use of its brand on social media sites? Focus areas
  • 44. Copyright © 2012 Deloitte Development LLC. All rights reserved.43 Assessing and auditing social media Auditing social media — people Loss of productivity Identity theft Social engineering Risk Example Controls Objective: Employees, contractors and customers are aware of their responsibilities relating to social media. Activities: • Establish user agreements for social media use • Conduct awareness training to inform users of the risks involved using social media websites • Use content-filtering technology such as DLP (Data Loss Prevention) • Limit access to social media sites Responsible parties: HR, Information Security HR policy violations
  • 45. Copyright © 2012 Deloitte Development LLC. All rights reserved.44 Assessing and auditing social media Auditing social media — process Reputational loss Regulatory compliance risk (i.e. copyright, trademark infringement, and privacy issues) False impression Risk Example Controls Objective: The enterprise brand is protected from negative publicity or regulation violation Activities: • Establish policies to determine legal- sensitive communications are tracked and archived • Conduct awareness training to inform users of the risks involved using social media websites • Scan the internet for misuse of the enterprise brand Responsible parties: HR, Information Security
  • 46. Copyright © 2012 Deloitte Development LLC. All rights reserved.45 Assessing and auditing social media Auditing social media — data Unauthorized disclosure Improper content Intellectual property leakage Risk Example Controls Objective: Enterprise information is protected from unauthorized access or leakage through/by social media. Activities: • Establish user agreements for social media sites • Develop policies on the use of enterprise- wide intellectual property • Determine if there is a capability to log the communications Responsible parties: Legal, HR, Information Security
  • 47. Copyright © 2012 Deloitte Development LLC. All rights reserved.46 Assessing and auditing social media Auditing social media — technology Constraining network bandwidth Virus/Worms via the social media sites Data theft from mobile devices Risk Example Controls Objective: IT infrastructure supports risks introduced by social media. Activities: • Install anti-virus applications on all systems including mobile devices • Use content-filtering technology such as DLP • Limit access to social media sites during business hours Responsible parties: Information Security
  • 48. Copyright © 2012 Deloitte Development LLC. All rights reserved.47 Assessing and auditing social media • Perform a study on what organization specific foot printing information is available on the Internet, and how it might be used to produce an exploit that targets the organization’s IT or Industrial Systems. The below assessments could be performed to in conjunction with a social media assessment to address other vulnerabilities, that could be related social media. Cyber threat profile analysis Suspicious program diagnostics • Use available industry hash data sets and cyber intelligence to match against a generated inventory of system files endeavoring to identify hidden exploits. Perform digital forensic analysis on suspect computers including examining system memory. Intranet cyber compromise diagnostic • Security event logs and infrastructure logs are analyzed to look for evidence of internal machines that may have been compromised and are attempting to communicate with miscreant controlled devices on the Internet. Anti-phishing capability diagnostic • Assess organizations’ anti-phishing program in order to help identify gaps and improvement opportunities. It includes looking at recent phishing incidents, intelligence services, and the organization’s incident handling procedures. Additional considerations
  • 50. Copyright © 2012 Deloitte Development LLC. All rights reserved.49 Assessing and auditing social media Group Topic Discuss at your table Share with the group Group 1 Governance and strategy • How is the area relevant to your organization? • Top three risks • Current Challenges • How you are addressing risks and challenges • Share other observations Group 2 Legal and regulatory compliance • What are key risks in this area? Group 3 Security and privacy • What are the controls that you are seeing to address these risks? Group 4 Brand and reputation management • Given the above, any interesting trends emerging? Working session
  • 52. Copyright © 2012 Deloitte Development LLC. All rights reserved.51 Assessing and auditing social media Khalid Wasti Director Deloitte & Touche LLP (212) 436-5156 kwasti@deloitte.com Contact info
  • 53. Copyright © 2012 Deloitte Development LLC. All rights reserved.52 Assessing and auditing social media • “Web 2.0 reinvents corporate networking.” Gopal, Raj, et al. Deloitte Consulting LLP • “Market Intelligence and Content Curating.” Eric Openshaw, Deloitte & Touche LLP • “Social Media Audit/Assurance Program” ISACA • “Social Media: Business Benefits and Security, Governance and Assurance Perspective” ISACA • “2012 Identity Fraud Report: Social Media and Mobile Forming the New Fraud Frontier” Javelin Strategy & Research • “Auditing Social Media: A Governance and Risk Guide” by Peter R. Scott and J. Mike Jacka • Statistics Brain: Social Network Statistics, www.statisticbrain.com/social-networking-statistics • Internal Auditor, “The Social Media Scene”, August 2012, Allison Cain References and additional resources
  • 54. About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting. Copyright © 2012 Deloitte Development LLC. All rights reserved. Member of Deloitte Touche Tohmatsu Limited