Do you think your company is ahead of the curve? Maybe you have social media policies in place. Perhaps you have training sessions twice a year to 
review social media do’s an don’ts and to sensitize your employees to appropriate behavior in social media. But what about your summer interns? Here today, gone tomorrow, summer interns should be subject to different social media policies from year round employees.
Certainly, there is little time to train summer interns. Their activities on social media may pose unusual risk for a company. Summer interns may have no idea that they have stumbled on confidential information. They usually do not understand about intellectual property protection or FTC Testimonial and Endorsement Guidelines. They may not have the maturity to separate their personal and professional social media activities. Yet, few companies have given thought to creating social media policies for their seasonal employees.
While I typically advocate for empowering employees to act as brand representatives in social media, I do not recommend such a philosophy with summer interns. At the same time, First Amendment rights do not allow a company to control personal postings. In addition, a summer intern who posts positively about his experiences at a company can be a public relations boon. Below are some suggestions for guiding summer interns in social media.
- Prohibit the summer intern from accessing personal social media pages on company equipment. Remind him that use of personal mobile devices could interfere with productivity expectations.
- Do not give the intern access to the company’s official social media pages without supervision and vetting of any posts.
- Clearly notify the summer intern that he is responsible for any post on his personal pages that reflects negatively on the company. Give him some specific examples rather than just stating policy.
- Allow the summer intern to mention his internship in his personal pages (e.g. interning at Company xyz).
- Encourage him to limit commentary to his own personal experience. Require a disclaimer in all social media posts that allude, even indirectly, to the company, his internship, or its products/services.
- Discourage any postings of any reviews of Company’s products/services, and remind him to post that he is currently employed as a summer intern if making any such reviews.
- Give specific advice about how to do disclaimers in space limited platforms such as Twitter. Include instruction on hashtags and links.
- Provide specific disclaimer language to the summer intern and show him how and when to use it.
- Have the summer intern sign an acknowledgement of these social media policies.
- If possible, on the first day of work, have the summer intern meet with a company representative to talk through your policies.
© Kyle-Beth Hilfer, P.C. 2011. Kyle-Beth Hilfer, Esq. specializes in advertising, marketing, promotions, intellectual property and new media law. She is also Of Counsel to Collen IP. For more information about her law practice, please visit www.kbhilferlaw.com.
If you’re interested in crafting a social media policy or learning how to best protect your organization consider attending the Social Media Legal Risks and Strategies Summit in San Francisco this October 4-6
