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Update on the Social Media Policies Database
My social media policies database is now up to 162 policies. I troll the internet periodically to add new policies as they become public. If you are looking to draft your own social media policy, the policies in the database are a good place to start. Currently they are organized into these industries Education (5)… » Read More
Massachusetts Amends Its Strict Data Privacy Law (Yet, Again)
Massachusetts has revised its data privacy regulations one more time. The revised regulations are less demanding that the original version released over a year ago. But this law is the strictest in the country and will be the de facto law of the land for many companies. Office of Consumer Affairs and Business Regulation released… » Read More
Workplace Computer Policy and the Attorney Client Privilege
Back in April, I mentioned a New Jersey case that found e-mail, sent during work hours on a company computer, was not protected by the attorney-client privilege: Compliance Policies and Email (Stengart v. Loving Care [.pdf]) That case has now been overturned. It seems that a company’s policy on computer use may be more limited… » Read More
Attorney-Client Privilege and Internal Investigations
Two cases illustrate some of the problems with the use of outside counsel for internal investigations. The possibility that a conflict of interest could arise when an attorney or law firm simultaneously represents an organization and one or more of its officers or directors is a recurring issue. A ruling earlier this month by U.S. District… » Read More
Ethical Integrity Leadership – Setting the Tone From The Top
EthicsPoint sponsored this webinar and these are my notes. Howard Sklar, Vice President & Global Anti-Corruption Leader, American Express Company was the presenter. Howard was quick to point out that it is not just the “tone” but having the right “tone.” Also, it not be just the tone “at” the top, but that it be… » Read More
Compliance and Recommendations on Social Networking Sites
I am an enthusiast of social networking sites and web 2.0. But I realize they have limitations and dangers. I have been very concerned about the Recommendations feature in LinkedIn. That feature allows any of your connections on LinkedIn to post a recommendation or endorsement about you that appears on your profile page. At first,… » Read More
Corporate Compliance Fraud in Georgia, Florida and Massachusetts
Just like the Corporate Compliance Fraud in Ohio, Compliance Services is also targeting companies in Georgia, Florida and Massachusetts. The Daily Citizen is reporting Georgia corporations warned about solicitations. The Georgia Secretary of State issued a warning: “Several corporations registered with the Corporations Division of the Office of the Secretary of State received a letter… » Read More
More Guidance on Extended COBRA Coverage under ARRA
As part of the enormous stimulus package in the American Recovery and Reinvestment Act of 2009, the federal government included some relief for laid-off employees: COBRA Coverage Under ARRA. Some of the unanswered questions are starting to be answered. The IRS has posted information: COBRA Health Insurance Continuation Premium Subsidy, with COBRA: Answers for Employers…. » Read More
FINRA’s Guide to the Internet
FINRA has published a Guide to the Internet for Registered Representatives. It paints a difficult picture for registered representatives wanting to use Web 2.0 tools. FINRA breaks internet activity into five main group for purposes or regulatory requirements: Publicly available Web sites (including banner advertisements, blogs and bulletin boards) are considered advertisements. An email or… » Read More
Blogging and Social Networking Policies
Here are some policies that I like for dealing with blogging and social networking sites: IBM Social Computing Guidelines – Blogs, wikis, social networks, virtual worlds and social media Cisco’s Internet Postings Policy Sun Microsystems: Sun Guidelines on Public Discourse BBC: Personal use of social networking and other third party websites (including blogging and personal… » Read More
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About
Compliance Building is published by Doug Cornelius, focusing on compliance and ethical issues for private equity real estate companies. Read more in About.
