Reputation Management in a New Age of Consumer Empowerment Frank Russo – Senior Vice President of Risk & Legal Affairs, Silverado Erica Swerdlow – Chief Executive Officer, Wye Communication Drew Graham – Partner Hall Booth Smith PC, Aging Services
Reputation Management • Reputation management refers to the influencing and controlling of an individual's or group's reputation • Should be managed proactively • Can’t be done during a crisis • Should be prepared for stages of issues and crisis • Growth of the internet and social media have made search results a core part of an individual's or group's reputation • Purchase decisions are made from content found in search • Monitoring is the key to effectively managing online reputation
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Why Be Prepared? • • • •
Company and personal reputation is at stake Get it right the first time Response is difficult without a plan Other parts of the business need to continue working effectively
• Leadership matters during a crisis • May help contain an issue before it becomes a communications crisis • Employees make mistakes because they don’t know what to do • “Thoughts & Prayers” and “no comment” is not an option A crisis never happens at a convenient time 3
An Issue Can Become a Crisis Quickly • • • • • •
Proliferation of phones and social media Social media content can go viral immediately More “news” outlets Scoop before facts A culture of us and them Lack of knowing what is being said
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The home’s administrator, Jorge Carballo, said in a statement that the transformer connected to the air-conditioning system had experienced a “prolonged power failure,” prompting the staff to contact Florida Power & Light. While waiting for a fix, he said, they set up mobile cooling units and fans and tried to make sure residents were hydrated and comfortable.
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We are devastated by these losses,” he said. “We are fully cooperating with all authorities and regulators to assess what went wrong.
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Positive Outcome from Hurricane Harvey Nursing Home Photo Gone Viral
Before
After
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Online Reputation Management Social media reputation management involves monitoring and improving a brand’s image on media platforms through: • Social listening • Use tools to monitor social sites, search and content • Deciding when and how to address content that is damaging • Employee vs. customer • Social footprint and following • When to take legal action • Feedback • Comment on positive reviews • Manage bad reviews • Don’t fake reviews • Encourage reviews but don’t bribe or ask everyone to do it
✓ Monitoring & Listening ✓ Responding (or not) appropriately ✓ Striving to do what’s right ✓ Reporting on progress & milestones
• Follow through 9
Legal Perspective
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May 7, 2016
“I looked very closely at your radiographs and it was obvious that you have cavities and gum disease that your other dentist has overlooked… You can live in a world of denial and simply believe what you want to hear from your other dentist or make an educated and informed decision.” https://www.propublica.org/article/stung-by-yelp-reviews-health-providers-spill-patient-secrets
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“[P]hysicians rarely win the Goldman, who has tracked about two dozen cases of doctors suing patients over online reviews, says physicians rarely win the cases and sometimes must pay the patients’ cases and sometimes must legal fees. pay the patients’ legal fees.” 12
How to respond to bad online reviews Consider responding offline
Speak about general policies if online
Manage your own online profile
Evaluate context
https://www.ama-assn.org/delivering-care/patient-support-advocacy/how-respond-bad-online-reviews
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How to respond to bad online reviews Don’t respond immediately
Understand how HIPAA applies
Consider mandated reporting
Don’t ignore criticism 14
Mandatory reporting laws (in all states except New York) require certain groups to tell designated authorities about reasonable suspicions of elder abuse.
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Crisis Scenarios • Employee-related event • Sexual abuse
• Natural disaster (hurricane, tornado, wildfire, flood, etc.) • Elopement with injury or death • Survey that results in a community closure or significant sanctions • Cybersecurity or significant privacy breach
• Communicable disease outbreak resulting in large numbers of resident and/or employee illness • Notorious lawsuits • Active shooting • Issues that can turn into crisis • Angry social media posts • Social posts with photo or video • Inappropriate control or responses of social channels 16
Recovery from an Incident • Ongoing positive content to push down negative comments and/or news coverage • New systems to prevent issue from becoming a crisis again • Social media policies • Social media monitoring • Preparedness plan • Ongoing investment in proactive reputation management
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Crisis Planning & Management
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Vulnerabilities Assessment & Risk Map • Review: • Current processes, including internal/external communication processes, organization structure and relevant external support • Parent company plan • Past media visibility (positive/negative) • Policies, processes and capabilities for managing digital/social media, e.g.: • Existing social media polices for corporate activity and employees • Existing social media platforms • Assessment of current ability to use digital media to manage crises • Opposition digital research • Determine new potential scenarios including those unique to your facility • Identify and prioritize reputational threats facing the company/industry
• Provide: • “Gap analysis” of existing crisis capabilities against best practices • Specific recommendations for crisis plan, content tools, systems and procedures to ensure your ability to respond effectively to media and all stakeholders in a crisis 19
Limited
Scope
Broad
Risk Level LEVEL 2 – LOW IMPACT Issues typically covered by national media outlets. However, this event may have a low impact on Facility’s stakeholder groups. Events of this nature have the likelihood to escalate to a higher impact situation based on the response of external stakeholders. Example: Senior living facility negative employee survey results brought to the attention of local broadcast station.
LEVEL 4 – HIGH IMPACT
LEVEL 1 – MINIMAL IMPACT Issue generates limited reactions from stakeholders. Often it will not significantly disrupt operations, create questions about Facility’s reputation or affect its relationship with stakeholders. Example: Patient wandered off and was unaccounted for for 4 hours, but was safely found and returned.
LEVEL 3 – MODERATE IMPACT High impact, but limited in scope. The number of customers affected is not incredibly large [thresholds to be determined] but the accusation could grow and be shared with local media, and social media coverage is possible. Example: One case of sexual abuse has come to the surface from a family.
Low
High impact situations have the most significant effect on Facility’s reputation, valuation and operations. These crises are covered by media outlets and on social media. The events deeply affect some or all of the bank’s stakeholders and they expect Facility to respond. Example: Two more people have died from Legionnaires’ disease at a retirement community, bringing total deaths to four and those sickened to 35. It is the largest Legionnaire’s outbreak in Franklin County in recent memory.
Level of Stakeholder Impact
High
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Strategies Produce Issues & Crisis Communications Plan • Use assessment tools to determine actions for severity and escalation points
IMPACT CRITERIA
POTENTIAL COMMUNICATIONS VEHICLES
▪ Media holding statement LEVEL 1 – MINIMAL IMPACT ▪ Internal communications as ▪ Less than [#] customers’ data affected, little needed system/website impact ▪ Possible customer letter or ▪ Potential economic impact to Facility less email than [$] ▪ No personally identifiable information affected ▪ Minimal or no media/social coverage LEVEL 2 – LOW IMPACT ▪ [# RANGE] customers’ data stolen or affected, low system/website impact ▪ Economic impact to Facility between [$ RANGE] ▪ Personally identifiable information including addresses, phone numbers and dates of birth may be affected ▪ Minimal media coverage (i.e. local or online) ▪ Minimal social media coverage (i.e. lower circulation blogs, Twitter posts from handles with low follower engagement, fewer than [THRESHOLD] posts on Facility’s Facebook page
▪ ▪ ▪ ▪ ▪
Customer letter or email Media holding statement Customer call scripts Possible news release Reactive social media messaging ▪ Employee communication ▪ Investor relations holding statement ▪ Overall messages and Q&A
KEY CONSIDERATIONS ▪ Is the incident “public” and/or does it have the likelihood to escalate? ▪ Is a response needed for our stakeholders? ▪ Is there pressure from certain stakeholder groups for a response? ▪ Are there misperceptions that could escalate the issue and damage Facility’s reputation? ▪ Are notices to consumers and regulators legally required? ▪ In what timeframe and with what criteria? ▪ Is the incident “public” and/or does it have the likelihood to escalate? ▪ Is a response needed for our stakeholders? ▪ Is there pressure from certain stakeholder groups for a response? ▪ Are there misperceptions that could escalate the issue and damage Facility’s reputation? ▪ Do customer-facing employees need additional support to handle inquiries? ▪ Are notices to consumers and regulators legally required? ▪ If law enforcement is involved, do they have a viewpoint on whether or how to go public?
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Audiences • • • • • • • •
Residents Survivors affected by the incident and their families Employees and their families News media Community – especially people living near the facility Company management, directors and investors Government elected officials, regulators and other authorities Vendors
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Messaging For each potential scenario/issue develop the following: • Message points • Media statement • Talking points for employees (note these may or may not be the same as media talking points) • Communications for families, community, partners, vendors • FAQs • Website or “dark site” content, as needed
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Media Communications Sample Statement (Cybersecurity Breach Scenario)
This holding statement is intended to be issued once a significant cybersecurity breach is detected, even if details of the situation are still largely unknown. It gives the basic facts about the breach and demonstrates that the Facility is actively dealing with the incident. “Protecting the privacy of our residents’ is the Facility’s top priority. We are aggressively investigating the scope and severity of a security breach that we believe has compromised resident information.
We are taking all possible steps to determine the impact of this incident and contain it. We will be in very close contact with our residents, their families and other interested parties as this unfolds to provide the timeliest information and deliver security solutions as fast as possible. We regret any inconvenience or anxiety this situation may cause our residents.
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Crisis Plan Creation Create comprehensive crisis plan, including: • Crisis management team and infrastructure • Key company messages • Crisis management policies, procedures and guidelines – including traditional and digital media and communications with all stakeholder audiences • Stakeholder inventory • Useful templates • Scenario-specific action plans • Hard-copy and digital versions of plans
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During an Issue or Crisis, Ensure You… • Demonstrate true, unquestionable care and concern • Be informative, address and answer, to the most extent possible, the key concerns of your stakeholders • Communicate consistently across all channels, stakeholder groups and regions • Communicate in plain English, not using corporate or legal talk
• Update as often as possible • Comply with appropriate jurisdictional laws and regulations 26
Thank you Erica Swerdlow, Wye Communications Erica.Swerdlow@wyecomm.com (847) 668-7011