Author: Elsa Abruzzo
Wow, what a busy week. It seems like things are picking up in the Medical Device industry and in general. Was your week as busy? One day, I will have to Blog off the GPP path and cover the work/life balance topic. I don’t know about you, but my social and family life these days are in a big turf war with my work/business life. This is a good place to be – I’m not complaining (really … knock-on-wood). However, I’m up to 2 Starbucks Venti (20 oz) Black-eyes (Coffee with 2 extra shots of espresso) each morning just to keep my energy up (and no, I get nothing from Starbucks for the plug –though free coffee would be nice). I can mention Starbucks to my heart’s content on this blog because I don’t work for them. Well, I hope you had time to digest last week’s Blog and are ready to continue on our social media drive.
Where were we… oh yes, we had covered safety features (establishing your GPP System/Plan and SOPs) and insurance (anticipating that anyone in your company can, unbeknownst to you, be involved in social media promotional activities that could be perceived as being tied to your company). So next and in keeping with our teenage driver analogy, we will cover “The spiel” on the rules.
The Spiel is a simple concept. As with your teenage driver, your employees need to not just know about, but really understand the rules — your policies on social media usage. Great SOPs are a necessity, but they are like Instructions for Use (IFUs), who really reads them unless they are forced to as part of required training, or worse, when there is an issue. In our previously blog post we discussed setting these expectations, but you have to communicate them to your employees in a way that will stick through proper training. The rules and expectations need to be clear and so do the consequences for breaking them. If you were dealing with your teenage driver you might let them know in very certain terms that the car (the big one with all the safety features that they are allowed to drive per the insurance coverage) can only be used for their drive to school and work and to social events only with prior permission (possibly from more than just one parent to make sure the old “Dad said I could” excuse doesn’t get thrown around later).
With social media, clearly train your employees that these can be construed as official company promotions. Let them know what is and isn’t allowed and how official company posts will be identified and controlled. You can’t keep employees from their personal use of social media. Likewise, it is unreasonable to think that your teenager will not use the car for non-school or non-work related travel. So you need to lay down the law before they are in an accident or get a ticket for driving after curfew. Your employees similarly need to understand the policies before you are faced with a warning letter from the FDA or a visit from the DOJ. Maybe your policy states that mention of your company or products in social media should be off-limits unless they are authorized to be part of these company communications. Unexpected use can come from all sorts of directions – take for instance a YouTube video where one of your employees is dancing a la Risky Business wearing an oxford button-down with your company logo prominently exposed. Well this may be more of an embarrassment than a regulatory risk – nevertheless, it is a cool example (no?). Wow, how can you cover such a scenario explicitly in your SOP? Maybe you can’t anticipate something so creatively and ingeniously troublesome. However, you can state that any indication of the company or product identity, which would of course cover your company logo on the oxford, is explicitly prohibited in non-company sanctioned social media use (which would include YouTube).
To ensure the driving rules and expectations are properly conveyed, have your teenager sign a contract with you stating that they understand and will abide by the rules and know and understand the consequences. This way there is no chance for the “I didn’t know that was against the rules” excuse. You signed the contract kiddo and even if you didn’t read it you acknowledged officially that you did and I’m holding you to your John Hancock. Now, if your kid takes the car for a social drive without your authorization, they know that they will lose their driving privileges for 2 weeks and will have to find rides to work and school. They signed a contract to this end making their whining and complaining less of an assault on your parental force field (yes one of my many super powers). With your employees the use of letters to the HR file, warnings, etc. may be an appropriate to place to start in terms of consequences. You may go on to list fines and even termination as consequences – depending on how grave the infraction.
Remind me to cover the sneaky teenager in a future Blog post. You know the type, the one that is so resourceful they customize the car’s audio system so that decibel levels can become an issue with the police and noise ordinances. There is also the crafty kid that soups up the car or changes the honk sound to a loud train horn without your even knowing it. You may laugh, but I assure you this can happen. You may not have such a kid (as I did), but you may have such an employee in your company. Really in the GPP world anything is plausible. I will try to give you some juicy examples later.
Well this week is a short blog. I hope you don’t mind. As always, this GPP Alliance Superhero wants your feedback. Till next week — same GPP time, same GPP place.