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Manulife Securities Social Media Supervision Tools

Manulife Securities is required to monitor advisor social media activity as it relates to dealer business. The platforms we monitor are

  • LinkedIn
  • Twitter
  • Facebook

We use a tool called Proofpoint Social Patrol to monitor and supervise social mediate activity.


Proofpoint Social Patrol:

Proofpoint Social Patrol provides Manulife Securities with the ability to monitor social media by connecting to your social media account, with your permission, and detecting any changes you make (updated profile, posts, etc.).  Any detected changes to profile content are routed to Manulife Securities Compliance for review and approval before they go live.  Posts and other content are scanned against risk-based tag lists, and if a piece of content is flagged, it is routed to Manulife Securities Compliance for review and approval before it goes live.  If a piece of content does not trigger a flag it does not come for review.

If you receive a communication from Manulife Securities requesting that you grant Proofpoint access to your social media account(s) we will need you to grant permission to Proofpoint. We require that you do this in order that we may connect to the account to monitor the activity. We do not connect to personal social media accounts, only accounts you associate with your business.

When Proofpoint attempts to connect to a social media platform, that platform may communicate to you certain regarding the kinds of access you are granting to Proofpoint.  Please note that:

  • these terms and permission statements are coming directly from the social media platform, and are not written by Proofpoint or Manulife Securities.
  • in some cases, the statements are broad, see samples at the end of this document along with explanations regarding the permissions you are being asked to grant to Proofpoint.

 

“Appendix A”

We have included below a list of the statements you can expect to receive from your social media platforms regarding the access you are granting to Proofpoint, along with additional explanation to clarify certain types of access. Proofpoint and Manulife Securities will only be using the access to your social media accounts to monitor and supervise your activity as required by the regulators.

LinkedIN’s permission statement/terms

Explanations for LinkedIN:

 

Proofpoint Social Patrol would like to:

  • Use your full profile including your experience, education, skills, and recommendations
  • Use the primary email address associated with your LinkedIn account
  • Use your 1st and 2nd degree connections' data
  • Use the email address, phone number, and other contact information associated with your LinkedIn account

Explanation: Proofpoint needs to capture content and profile information for supervision and archiving purposes.


  • Retrieve and post updates to LinkedIn as you

Explanation: Proofpoint retrieves updates, but it does not post. LinkedIn treats “retrieving” and “posting” under the same permission, however Proofpoint does not post.


  • Retrieve and post group discussions to LinkedIn as you

Explanation: Similar to above. Proofpoint retrieves group discussions, but it does not post.


  • Send messages and invitations to connect as you

Explanation: Similar to above. Proofpoint does not send messages and invitations as the advisor but needs the permission to capture messages and invitations. It only captures messages sent by the advisor not messages received by the advisor.


  • Use your activity for compliance monitoring and archiving
  • Edit profile fields including your photo, headline, summary, and work and education history

Explanation: Proofpoint needs the ability to edit profile fields.

i.e., When Profile changes are rejected and need to revert back to their last approved state.

i.e., When Profile changes are approved in Pre-review mode, then ProofPoint will update to being live on the social network.


  • Manage and delete your data including your profile, posts, invitations, and messages

Explanation: Proofpoint can delete content (manually or automatically) if there is a compliance violation or some other type of risk is detected (i.e., profanity or malware).  Proofpoint cannot delete invitations and messages – only public posts.


Twitter’s permission statement/terms

Proofpoint Social Patrol will be able to:

  • Read Tweets from your timeline.

Explanation: Proofpoint needs to capture content for supervision and archiving purposes.


  • See who you follow, and follow new people.

Explanation: Proofpoint has this permission for corporate and business type accounts that wish to block users from commenting. This functionality is not used by Manulife Securities Compliance. Proofpoint will never follow new people.

  • Update your profile.

Explanation: Proofpoint needs the ability to edit profile fields for the following use cases:

  1. Profile changes are rejected by Manulife Securities Compliance and need to revert back to their last approved state.
  2. Profile changes are approved and posted live on the social network.
  3. Post Tweets for you.

Explanation: Proofpoint never Posts Tweets on the user’s behalf.


  • Access your direct messages.

Explanation: Proofpoint needs to capture direct messages for supervision and archiving purposes. It only captures your messages not messages received.


Facebook permission statement and terms


Proofpoint Social Patrol would like to:

  • Manage your Pages

Explanation: Proofpoint needs to capture content and profile information for supervision and archiving purposes.

Proofpoint needs the ability to edit profile fields for the following use cases:

  • Profile changes are rejected by Manulife Securities Compliance and need to revert back to their last approved state.
  • Profile changes are approved and posted live on the social network.
  • Publish as Pages you manage

Explanation: Proofpoint never Publishes content on the user’s behalf.


  • Access your Facebook Pages’ messages

Explanation: Proofpoint needs to capture messages for supervision and archiving purposes. It only captures messages by you not messages received.