It’s always useful to look at what your competition is doing. The same is true in drafting your code of conduct (or code of...
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New Social Media Policies Database
I assembled a collection of social media policies: Social Media Policies Database.
So far I have 117 a bunch in the database. That’s a very small number, but I think most companies want to keep their policies private. If I am missing any, please leave a comment letting me or send me an email: compliancebuilding@gmail.com.
I...
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Private Fund Investment Advisers Registration Act Status
OpenCongress allows you to create custom widgets for the status of bills in Congress. I decided to play around and create one for the House version of the Private Fund Investment Advisers Registration Act.
oc_host_url = "http://www.opencongress.org/";
oc_bill_id = "111-h3818";
oc_frame_height = "205";
oc_bgcolor = "ffffff";
oc_textcolor = "3153e7";
oc_bordercolor = "153e7e";
I’ll create one for the Senate version once they...
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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...
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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 ) That case has now been overturned. It seems that a company’s policy on computer use may be more...
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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...
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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,...
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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 from...
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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.
The...
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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 instant...
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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 web-space) (.pdf)
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