Romenesko Misc.
The Orange County Register parent says it "encourages its associates to participate in these [social] media as a means of generating interest in the Company’s products and services and creating business opportunities," but "the Company must ensure that use of these communications maintains its brand identity, integrity and reputation while minimizing actual or potential legal risks, whether used internally or externally." All employees must sign the policy. (It's reprinted after the jump.)

FREEDOM COMMUNICATIONS, INC.

POLICY: Social Media Policy
EFFECTIVE DATE: February 2011

SCOPE
This policy applies to all Freedom Communications, Inc. associates.

PURPOSE
The Company recognizes that the internet provides unique opportunities to participate in interactive discussions and share information on particular topics using a wide variety of social media such as Facebook, Twitter, blogs, wikis, chat rooms and other similar forms of online journals, diaries or personal newsletters not affiliated with Freedom Communications, Inc. However, associates’ use of social media can pose risks to the Company’s confidential and proprietary information, reputation and brands and can jeopardize the Company’s compliance with business rules and laws applicable to our industry.

To minimize these business and legal risks, to avoid loss of productivity and distraction from associates’ job performance and to ensure that the Company’s IT resources and communication systems are used only for appropriate business purposes, Freedom Communications, Inc. expects all its associates to adhere to the following rules and guidelines regarding use of social media.

GENERAL PROVISIONS
Social media includes the following, but is not limited to, video, wiki postings, Facebook, Twitter, chat rooms, personal blogs or other similar forms of online journals, diaries or personal newsletters not affiliated with Freedom Communications, Inc.

Unless specifically instructed, associates are not authorized, and therefore restricted, to speak on behalf of the Company. Associates may not publicly discuss clients, products, associates or any work-related matters, whether confidential or not, outside company-authorized communications. Associates are expected to protect the privacy of Freedom Communications, Inc., its associates, its clients, etc. and are prohibited from disclosing personal associate and non-associate information and any other proprietary and nonpublic information to which associates have access. Such information includes, but is not limited to, customer information, trade secrets, financial data, strategic business plans, etc.

AUTHORIZED SOCIAL NETWORKING
Apart from personal use of social media in accordance with this policy, The Company encourages its associates to participate in these media as a means of generating interest in the Company’s products and services and creating business opportunities by promoting and raising awareness of the Freedom Communications, Inc. brands, search for potential new markets, communicate with associates and customers, to brainstorm issues or respond to breaking news or publicity and discuss corporate, business-unit and department-specific activities and events.

When social networking, blogging or using other forms of web-based forums, the Company must ensure that use of these communications maintains its brand identity, integrity and reputation while minimizing actual or potential legal risks, whether used internally or externally.

COMPLIANCE WITH RELATED POLICIES AND AGREEMENTS
All of the Company’s other policies that might apply to the use of social media remain in full force and effect. Associates should always adhere to these policies when using social media. In particular, the following policies should be kept in mind:

* Anti-Discrimination and Harassment Policy
* Code of Business Conduct
* Confidentiality and Proprietary Information
* Equal Employment Opportunity Policy
* Information Technology and Security Policy
* Prevention of Workplace Violence Policy
* Vehicle Safety Cell Phone and PDA Use Policy
* Workplace Safety Policy

Social media should never be used in a way that violates any other Freedom Communications, Inc. policies or employee obligations. If your post would violate any of the Company’s policies in another forum, it will also violate them in an online forum. For example, associates are prohibited from using social media to:

* Violate Freedom Communications, Inc.’s IT resources and communication systems policies.
* Violate Freedom Communications, Inc.’s confidentiality and proprietary rights policies.
* Circumvent Freedom Communications, Inc.’s ethics and standards of conduct policies.
* Defame or disparage Freedom Communications, Inc. or its affiliates, customers, clients, business partners, suppliers, vendors or other stakeholders.
* Harass other associates in any way.
* Circumvent policies prohibiting unlawful discrimination against current associates or applicants for employment.
* Violate Freedom Communications, Inc.’s privacy policies (for example, never access private password protected sites of co-workers or other Freedom Communications, Inc. stakeholders without permission).
* Violate any other laws or ethical standards (for example, never use social media in a false or misleading way, such as by claiming to be someone other than yourself or by creating an artificial “buzz” around our business, products or services).

Associates who violate Freedom Communications, Inc. policies will be subject to discipline, up to and including termination of employment.

PERSONAL USE OF SOCIAL MEDIA
We recognize that associates might work long hours and occasionally may desire to use social media for personal activities at work or by means of the Company’s computers, networks and other IT resources and communications systems. The Company authorizes such occasional use so long as it does not involve unprofessional or inappropriate content and does not interfere with your employment responsibilities or productivity. Circulating or posting commercial, personal, religious or political solicitations, or promotion of outside organizations unrelated to the Company’s business are also prohibited.

NO EXPECTATION OF PRIVACY
All contents of Freedom Communications, Inc.’s IT resources and communications systems are the property of the Company. Therefore, associates should have no expectation of privacy whatsoever in any message, files, data, document, facsimile, telephone conversation, social media post, conversation or message, or any other kind of information or communications transmitted to, received or printed from, or stored or recorded on the Company’s electronic information and communications systems. You are expressly advised that in order to prevent misuse, Freedom Communications, Inc. reserves the right to monitor, intercept and review, without further notice, every associate’s activities using the Company’s IT resources and communications systems, including but not limited to social media postings and activities, and you consent to such monitoring by your acknowledgement of this policy and your use of such resources and systems. This might include, without limitation, the monitoring, interception, accessing, recording, disclosing, inspecting, reviewing, retrieving and printing of transactions, messages, communications, postings, log-ins, recordings and other uses of the systems as well as keystroke capturing and other network monitoring technologies.

The Company also may store copies of such data or communications for a period of time after they are created, and may delete such copies from time to time without notice.

Do not use the Company IT resources and communications systems for any matter that you desire to be kept private or confidential from the Company.

The Company reserves the right to use content management tools to monitor, review or block content on social network sites that violate company policies and procedures.

VIOLATIONS

Reporting Violations
The Company requests and strongly encourages associates to report any violations or perceived violations of this policy to supervisors, managers or Human Resources. Violations include discussions of the Company, its associates and clients, any discussion of proprietary information and any unlawful activity related to blogging, social networking, etc. as outlined in this policy.

Discipline for Violations
The Company investigates and responds to all reports of violations related to social networking and other related policies. Violation of the Company’s social media policy will result in disciplinary action, up to and including termination. Discipline will be determined based on the nature and factors of any blog, social networking, etc.

Freedom Communications, Inc. reserves the right to take legal action where necessary against associates who engage in prohibited or unlawful conduct.

Associates are required to sign a written acknowledgement that they have received, read, and understood and agreed to comply with the Company’s social media policy and any other related policy.

GUIDELINES FOR ASSOCIATES’ RESPONSIBLE USE OF SOCIAL MEDIA
The above material covers specific rules, policies and contractual obligations that associates must follow in using social media, whether for personal or business purposes, in consideration of their employment and subject to discipline for violations. The following sections of the policy provide associates with common-sense guidelines and recommendations for using social media responsibly and safely, in the best interests of Freedom Communications, Inc. These guidelines reflect the “duty of loyalty” every associate owes it’s employer, and are intended to add to, not contradict, limit or replace, the applicable mandatory rules, policies and contractual obligations above.

PROTECT THE COMPANY’S GOODWILL, BRANDS AND BUSINESS REPUTATION.
Freedom Communications, Inc.’s Associate Handbook/Confidentiality and Proprietary Rights policy prohibits you from posting disparaging or defamatory statements about the company or its business interests, but you should also avoid social media communications that might be misconstrued in a way that could damage the company’s goodwill and business reputation, even indirectly.

Make it clear in your social media postings that you are speaking on your own behalf. Write in the first person and use your personal e-mail address when communicating via social media. You are personally responsible for what you communicate in social media. Remember that what you publish might be available to be read by the masses (including the Company itself, future employers, and social acquaintances) for a long time. Keep this in mind before you post content.

If you disclose your affiliation as an associate of Freedom Communications, Inc., it is recommended that you also include a disclaimer that your views do not represent those of your employer. For example, consider such language as “the views in this posting do not represent the views of my employer”.

If you communicate about your work or Freedom Communications, Inc. in general, you should disclose your connection to and role at Freedom Communications, Inc., but be sure to reiterate that your views do not necessarily represent those of Freedom Communications, Inc. Use good judgment about what you post and remember that anything you say can reflect on Freedom Communications, Inc., even if you do include a disclaimer. Always strive to be accurate in your communications about Freedom Communications, Inc. and remember that your statements have the potential to result in liability for yourself or Freedom Communications, Inc. Be respectful to Freedom Communications, Inc. and be professional and honest in your communications.

If you are uncertain or concerned about the appropriateness of any statement or posting, refrain from making the communication until you discuss it with your supervisor or Human Resources.

If you see content in social media that disparages or reflects poorly on Freedom Communications, Inc. or its stakeholders, you should contact your supervisor or Human Resources. Protecting Freedom Communications, Inc.’s goodwill, brands and reputation is every associate’s job.

RESPECT INTELLECTUAL PROPERTY AND CONFIDENTIAL INFORMATION.
Freedom Communications, Inc.’s Confidentiality and Proprietary Rights Agreement/Associate Handbook restricts associate’s use and disclosure of the company’s confidential information and intellectual property. Beyond these mandatory restrictions, you should treat the company’s valuable trade secrets and other confidential information and intellectual property accordingly and not do anything to jeopardize them through your use of social media. In addition, you should avoid misappropriating or infringing the intellectual property of other companies and individuals, which can create liability for yourself and for Freedom Communications, Inc.

Do not use the Company’s logos, brand names, taglines, slogans or other trademarks, or post any confidential or proprietary information of the Company, without prior written permission from the Freedom Communications, Inc. legal department.

To protect yourself and the Company against liability for copyright infringement, where appropriate, reference sources of particular information you post or upload and cite them accurately. If you have any questions about whether a particular post or upload might violate the copyright or trademark of any person or company (outside of “fair use” exceptions), ask the Freedom Communications, Inc. legal department before making the communication.

RESPECT YOUR COWORKERS AND OTHER FREEDOM COMMUNICATIONS, INC. STAKEHOLDERS.
Do not post anything that your co-workers or Freedom Communications, Inc.’s customers, clients, business partners, suppliers, vendors or other Freedom Communications, Inc.’s stakeholders would find offensive, including ethnic slurs, sexist comments, discriminatory comments, insults or obscenity.

Do not post anything related to your co-workers or Freedom Communications, Inc.’s customers, clients, business partners, suppliers, vendors or other Freedom Communications, Inc. stakeholders without their written permission.

ACKNOWLEDGEMENT OF RECEIPT AND REVIEW

I have received and read a copy of the Freedom Communications, Inc. Social Media Policy and understand its contents. I understand that Freedom Communications, Inc. expressly reserves the right to change, modify or delete its provisions without notice.

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Associate Name

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Date

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Associate Signature