'What should I tell them?' Why every organization should have an official policy for communicating.

A well-formed communication policy is to your organization what the IABC Code of Ethics is to you: a set of guiding principles and behaviors to help ensure consistent, fair and ethical communication with all of your constituents. Few organizations have written communication policies and even fewer share those policies broadly within or beyond the organization.

But that doesn't negate the need for such an important document. "All firms with more than one employee should have a clearly written media policy that spells out who in the organization may respond to media inquiries, what kinds of information can or should be released to reporters and what information must be kept confidential," write David M. Freedman and Janice E. Purtell in an article published by Media Relations Central, an online resource for media relations professionals.

Beyond the media, companies and organizations also need to consider their other audiences who expect to hear official positions and responses, or at various business junctures or when news breaks.

So whether they're called media relations, disclosure, public relations or public information policies, there are common elements of communication policies that can help guide you and your leadership to the development of a formal, written and agreed-upon procedure for communicating both internally and externally.

POLICY BY BEHAVIOR

Your organization may already have a communication policy, albeit unstated, as seen in your overall behavior and attitude toward your constituencies.

Customers, employees, reporters, investors and community leaders make judgment calls about your organization's stance on communication based on what they see, hear and read.

For example, if your organization is a solid "no comment" in the media, a reader may decide that your company is close-minded, engaging in illegal or unethical activities or just not friendly.

Conversely, if your corporate logo is on T-shirts worn by company volunteers cleaning a park, passersby may judge your company to be community-spirited and your employees happy to work for you.

If your process for responding to inquiries from the media is complex, or delays or denies access to executives, reporters may assume that you and your company are hiding something.

You'll also find an undeclared policy in the language and style used in the written pieces disseminated by your organization, including employee communication, advertising, product return policies, workplace guidelines, benefits materials and speeches. Your communication policy might be evident in the company's level of involvement in the community, its rules for workplace advancement and training, its media guidelines and activity or the conduct of your annual meeting.

It's vital that you determine what your perceived communication policy is before you begin developing a formal, written one.

WHAT POLICIES CAN DO

Written policies can define your communication philosophy (e.g., proactive) as well as your practices (the role of the primary spokesperson) and procedures (how to respond to media inquiries).

When helping her clients in South Africa develop a full communication strategy, management consultant Amanda Hamilton-Attwell, Ph.D., says that developing a clear communication policy is part of the bigger process that includes the "integration and alignment of communication processes, projects, activities and image." Her definition of a communication policy is straightforward: "The rules that will determine the behaviour of the communication specialists and the management of the flow of information."

Policies can be developed for general communication and/or for specific areas such as financial communication or legal communication.

Formal policies can take the guesswork out of trying to manage an active media relations program--you shouldn't be writing the policy while the reporter is on the telephone.

"A clearly written media policy can help to minimize your firm's media liabilities and promote a positive public perception of your firm--it's all in what you say and how you say it," according to Freedman and Purtell.

Finally, communication policies can both reflect and guide your organization's code of conduct, code of ethics, business principles or even the mission statement.

COMMUNICATION PHILOSOPHY STATEMENTS

Some organizations have simple policy rules and procedures led by a definitive statement of their guiding philosophy on communication.

The European Bank for Reconstruction and Development makes such a statement: "The Bank continues to be guided by the underlying presumption that, whenever possible, information concerning the Bank's operational activities will be made available to the public in the absence of a compelling reason for confidentiality."

Duke Energy, a U.S. power company, takes a similar stance with a more concise statement: "Duke Energy will foster open dialogue and informed decision making through meaningful and regular communication of [Environmental, Health & Safety Policy] information with management, employees and the public."

The policy of the European Investment Bank recognizes the public trust responsibility: "Acknowledging that the public has an interest in the activities of the EIB, the Bank's public information policy aims to support one of the EIB's key corporate objectives: to achieve a high level of transparency of its activities and communicate effectively with all stakeholders."

Daniela Wortmann of EIB explains that although this policy is available for all to read, the policy actually "is created at a European Union level, by the EU governments (European Union Council, the European Parliament and the European Commission)."

In the United States, activities of a tax-supported institution (with some exceptions) are available to the public. North Carolina State University's communication policy reflects that status: "as a public university supported with tax dollars, [N.C. State] has a responsibility to be open and responsive to information requests from the public and the news media."

The university further clarifies its position by adding that it is "committed to a policy of openness, honesty and cooperation with members of the public and the news media."

Imperial Oil, one of Canada's largest corporations, is focused on disclosure as the basis of its policy statement. The company is "committed to a policy of full, true and plain public disclosure of all material information in a timely manner in order to keep security holders and the investing public informed about the company's operations."

The Seattle Cancer Care Alliance in Washington state begins its policy with this goal: "to facilitate and encourage open and positive relationships between SCCA staff and the media while ensuring that all communications result in an accurate and appropriate portrayal of the SCCA activities."

Perhaps the simplest, most concise philosophy statement comes from the Gloucestershire Partnership NHS Trust in England: "The policy establishes the basis of the desired relationship with the local, regional and national media, one that is 'open, effective and positive.'"

Opening statements such as these are essential in setting the standard for the organization's communication policy and for developing the procedures and practices in support of that philosophy.

MEDIA RELATIONS AND SPOKESPERSON POLICIES

Among associations and organizations, the most common communication policy is directed specifically to media relations.

The Special Libraries Association offers a detailed procedure and practices policy for dealing with the media. From identifying the primary media contact (the association's director of public relations) to what to do upon receiving a call directly from the media (contact the director of public relations), the SLA offers a step-by-step procedure easy enough for any employee to follow.

The association even details how to respond to inaccurate or incomplete media coverage, how to respond to other types of media inquiries (such as requests for press credentials, press kits and review copies of SLA publications) and the rules of initiating communication with the media.

The SLA also lists backup systems, should the director of public relations be unavailable or in case the inquiry raises an issue on which the association has no previous recorded statement or policy.

To ensure coordinated news releases, North Carolina State University's policy on media relations states, "only three divisions of the university are authorized to issue news releases or to hold news conferences on behalf of the university."

However, as a service to reporters, the university also makes clear what is considered public information and what is not, in accordance with U.S. and North Carolina laws regarding state personnel privacy, student privacy and library users' disclosures.

Jackson State University in Mississippi states clearly in the first paragraph of the University Publicity Policy that, "The President and the Director of Public Relations are the University's official spokespersons unless otherwise designated."

The Office of Public Relations additionally provides guidelines for faculty and staff who might be called directly by the media, and the policy outlines what JSU faculty and staff need to do if they want a news release or public service announcement issued from their departments.

Imperial Oil also is clear about who speaks to the media but, as a large entity, offers more options: "The primary spokespersons for the company are the chief executive officer; controller and senior vice-president, finance and administration; senior vice-president, resources division; senior vice-president, products and chemicals division; director, corporate planning and communications; investor relations manager; and public affairs manager."

Because its policy is more focused on disclosure, Imperial Oil provides a definition of "material information," a procedure timeline for disclosure, suggestions on how to respond to rumors and a discussion of communication with financial analysts and investors.

Perhaps of most importance to Imperial Oil's employees is this overarching guidance: "If there is any doubt about the appropriateness of supplying information to an outside party, an employee should contact investor relations for advice."

PROCEDURES AND PRACTICES

Media relations and other communication policies take the guesswork out of many activities related to working with reporters, analysts and the public.

The Gloucestershire Partnership NHS Trust has a 10-page media relations policy. The detail in this lengthy policy, available online, expertly covers why the media are interested in health, general principles that underpin the policy (e.g., "The duty of care and protection of a patient's right to privacy, dignity and confidentiality must come first on every occasion."), what to do when receiving media inquiries, how to handle requests for interviews and/or photographs with patients, press briefings, guidance for spokespeople, the spokesperson's rights when being interviewed as well as how to write a news release.

This is as good a primer as you'll find anywhere. What makes it special is its strong link to the philosophy of open communication.

Brock University of St. Catharines, Ontario, Canada, takes a simpler approach with its one page media relations policy that includes a preamble and seven policy procedures covering who will speak to the media and how media should approach the university with inquiries. This centrally controlled media relations program works well in a small organization but might not be advisable for a larger, more dispersed company.

The city of Chula Vista, Calif., provides yet another view on how to construct a communication policy and procedures by acknowledging, "One of the most effective and quickest ways to communicate City policies and activities to its citizens is by working in partnership with the news media."

This statement is followed by a list of authorized spokespersons and instructions on what to do when a reporter calls; how to handle sensitive or controversial matters; litigation, personnel and election issues; general or routine news; public safety; and crisis or emergency situations.

The city of Chula Vista also reminds employees that because "the media work on tight deadlines, it is important that all departments respond as soon as possible when the Office of Communications requests department information or a spokesperson for the media."

Cincinnati Children's Hospital Medical Center doesn't state a philosophy about its media relations approach but does detail the responsibilities of both the media relations staff and reporters. It also cites federal laws that prohibit or limit the amount of information that can be given to reporters.

Of special note, the medical center's online guidelines include PDF files of required release forms for photography and disclosure of protected health information. Making the forms easily accessible assists both the media and internal staff who work with the press. The hospital media relations department also gives instructions on how to download faculty/staff photographs from the hospital web site. Both of these additions-not commonly seen in other published media relations policies and procedures--show a clear understanding of the media's needs.

Although the Iowa State University Foundation states that "most information concerning administrative, financial, fundraising and stewardship, investments, and distribution of funds by the foundation are voluntarily made public," it, nonetheless, details exactly what is publicly available and what information is available on request.

FINAL THOUGHT

Whether you take the approach of preparing general guidelines or prefer a more detailed document, a communication policy--available to internal and external audiences--effectively demonstrates your organization's stance on open, honest and ethical communication.

One of the earliest--and perhaps still the best--written communication policies was penned by Theodore Vail, the first president of AT&T, who wrote:

"The only policy to govern the publicity of AT&T is that whatever is said or told should be absolutely correct, and that no material fact, even if unfavorable but bearing on the subject, should be held back. When we see misstatements, make it certain that those making them have the correct facts. This will not only tend to stop the making of them but will lessen the influence of them by decreasing the number of misinformed, and any excuse for misstatements. Attempted concealment of material fact cannot but be harmful in the end."

It's as strong a statement today as it was 100 years ago.

TWO-DOZEN RULES FOR RESPONDING TO MEDIA QUERIES

Organizations with more than one employee should have a clearly written media policy that spells out who may respond to media inquiries, what kinds of information can or should be released to reporters and what must be kept confidential.

A good media policy should include most or all of the following elements:

1. List who in the company may respond to media inquiries, and to whom others should direct media inquiries.

2. Be familiar with the publication or broadcast that the reporter represents.

3. Treat reporters courteously. Their impression of each person in your firm affects how they perceive the entire organization and may influence how they report about you.

4. Return reporters' calls within an hour, if possible. They are usually on tight deadlines.

5. Briefly explain to the media who you are and what you do. Prepare a short statement for authorized representatives to refer to.

6. Speak in a way that average readers and listeners can understand. Avoid industry jargon or bureaucratic language.

7. Your media relations policy should indicate what data or information must remain confidential.

8. Feel free to ask the reporter questions about the story--the theme, the point of view, who else is being interviewed.

9. If information is already a matter of public record, don't hesitate to share it. Withholding such information will only force the reporter to develop other sources.

10. Always be truthful and accurate. Never exaggerate or inflate. Understatement usually works better than hyperbole. Trust is key to good media relations.

11. Discuss with reporters only what is in your area of expertise. Do not speculate. If you don't have personal knowledge about a subject, suggest a reliable source.

12. When you talk to a reporter, remember that you're really talking to the public.

13. If you need time to research or think about how to answer a question, it's fine to say so. Just arrange a deadline for providing the additional information to the reporter.

14. Avoid disparaging other companies or defaming other people. Not only is it actionable, but it also makes you appear unprofessional.

15. Refer media questions about your firm's policies or political views to the firm's designated executive or spokesperson.

16. If you cannot answer a question, make sure the reporter understands why.

17. Keep it simple. If you finish answering the question and the reporter remains silent, don't feel pressured to elaborate. It may only serve to dilute your message.

18. If a reporter asks about a pending lawsuit or criminal action, it's normally not advisable--and in many cases it's improper--to discuss it.

19. Take notes on the interview and promptly send them on to a designated executive, allowing for additional information or clarification. If you plan to record the interview, ask the reporter's permission.

20. Assume that everything you say to a reporter is on the record. If you don't want to see it in print or on the air, don't say it.

21. Don't argue with the reporter. You can be persuasive, but never confrontational.

22. Don't ask the reporter if you can review the story before it's published. If the story is highly controversial, ask the reporter to read back your quotes to confirm accuracy.

23. Don't infringe on a reporter's right to report on and photograph newsworthy events or statements made in public.

24. Ignore minor factual errors or omissions in the published story. If it seriously misrepresents your position or misstates an important fact, politely request a correction.

This annotated version of "Say What? Write a Media Relations Policy for Your Firm," by David M. Freeman and Janice E. Purtell, is available in its entirety at www.dmfreedman.com/pr-policy.shtml. Freedman is a Chicago-based writer, newsletter developer and media relations consultant and can be reached at [e-mail]. Purtell is the founder and president of JP Consulting located in Richfield, Wis. She assists professional service organizations in planning and developing marketing programs and systems, and can be reached at [e-mail].

JUST ANSWER THE QUESTIONS, THANK YOU

One of the most important provisions of a good media relations policy is that when a reporter asks you a question, assuming you have the authority to answer it, you should respond truthfully and accurately, and then shut up. Don't try to steer the interview in another direction; you'll only frustrate the reporter, who can always find another source of information.

Prepare a brief statement in advance. The statement should explain who you are and what your company does, similar to the boilerplate information you include at the end of a press release. Beyond that statement, however, do not talk about yourself unless the reporter asks. Your goal as a spokesperson is to establish your organization as a reliable source of news and background information. Violating this policy can have serious consequences.

Avoid a bad reputation. A few years ago, an international scientific institute held a weekend conference in Chicago, and asked me to help publicize the event. The keynote speaker was a world-famous scientist who had recently returned from an international lecture tour. I set up an interview with him for a Chicago Tribune reporter just before the conference started.

The institute's director attended the interview, along with the reporter, the scientist and me. During the interview, which focused primarily on the scientist's illustrious career, and particularly his recent meeting with Nobel Prize winners in Europe, the director repeatedly urged the reporter to ask the scientist about the keynote speech he planned to give later that evening, and about the conference in general, to the point that this imploring became disruptive. A few days later the reporter told me confidentially that he would never again conduct an interview with that director in the room. The article that appeared in the following Sunday edition of the Tribune barely mentioned the institute and its conference.

Don't focus on your agenda. Another example of media relations gone awry involves a big Midwest law firm--let's call it The Firm--that was defending a major corporation in a wrongful death lawsuit. In fact, the claim for damages was so huge that the corporation had hired two law firms for its defense. After months of litigation, the judge dismissed the case based on arguments made in a brief that one of the lawyers from The Firm had written. The defendant and its two law firms decided that this brief-writing lawyer (BWL) would be the spokesperson for press inquiries. A reporter finally called him, intending to ask questions about the issues in the case, the social implications of the judge's decision and how the decision might affect other companies in the same industry, for example. But BWL tried to steer the conversation to his brief and his firm's representation of the defendant. The reporter finally gave up and called the other defense firm for comments.

Prove your value. Now, there are some media trainers who teach spokespersons to subtly steer reporters in certain directions that serve their own purposes, and in some cases this can be done without alienating the reporter. But it takes a lot of training to be able to do that well, and you have to know when to back off and let the reporter maintian control.

In most cases, your value to the news media depends on your ability to provide the information they need to do their jobs well. If you prove your value in that respect, the press will contact you again and again, whether it's a story that involves your company, or when they simply need background information.

Dave Freedman is a Chicago-based free-lance journalist and media relations consultant (www.dmfreedman.com). He is also the president of Eminent Publishing Co. (www.empub.com).

COMMUNICATION POLICIES AVAILABLE ONLINE

Sample communication policies, taking various approaches, can be found online as posted by the following companies and organizations.

> Brock University of St. Catharines, Ontario, Canada www.brocku.ca

> Cincinnati Children's Hospital Medical Center www.cincinnatichildrens.org

> City of Chula Vista, Calif. www.chulavistaca.gov

> Duke Energy www.duke-energy.com

> European Bank for Reconstruction and Development www.ebrd.com/new/index.htm

> European Investment Bank www.eib.org

> Gloucestershire Partnership NHS Trust www.partnershiptrust.org.uk

> Imperial Oil www.imperialoil.com

> Iowa State University Foundation www.foundation.iastate.edu

> Jackson State University http://ccaix.jsums.edu/~edlga/opr/publicity-policy.htm

> North Carolina State University www.ncsu.

> Seattle Cancer Care Alliance www.seattlecca.org

> Special Libraries Association www.sla.org

Wilma Mathews, ABC, director of public relations for Arizona State University, has published numerous articles on media relations, communication planning and measurement. She can be reached at [e-mail].