Why Social Media Recordkeeping Matters
Government agencies, financial institutions, and regulated organizations are increasingly expected to capture and retain records of their official social media activity—just like they do with email and websites.
However, social media is an ever-evolving data source that can create endless records that are outdated almost as soon as they are collected.
Just consider, for example, a simple Facebook post. The post itself can be edited (or deleted), link out to external content, receive thousands of likes and shares, and invite hundreds of comments. With every new like and comment, a new record is created.
When it comes to proving regulatory compliance and preparing for litigation, the implications are pretty significant.
How should all this information be monitored, collected, processed, secured, and archived to ensure that it is easily available when needed?
From a compliance and legal standpoint, social media records must be archived in a way that is:
- Accurate and reflects the context of the content
- Authentic and verifiable with metadata and digital signatures
- Accessible for audits, eDiscovery, or FOIA/open records requests.
An inability to adequately capture and produce social media records can result in skyrocketing litigation costs, sanctions, regulatory penalties, and even loss of trust with the public.
To assist with this challenge, we’ve created an information governance model that specifically addresses data from online sources like social media.
In this guide, we share exactly how information should be created, retained, managed, & disposed of.
The Primary Challenges of Social Media Recordkeeping
Despite the fact that many organizations need to keep detailed social media records for litigation and compliance, many still fail. Modern recordkeeping for these kinds of unstructured data sources is actually incredibly complex, and on top of that, companies often struggle to understand exactly what is required.
Here are the main hurdles organizations face when trying to create compliant, litigation-ready social media records:
1. Constant Change
Facebook doesn’t look the same as it did even just a few years ago. And platforms like Twitter (now X) have completely changed, seemingly overnight. New platforms like Bluesky are gaining traction, and the incredible popularity of video-first platforms like TikTok are driving widespread change across the social media landscape.
But that’s just the platforms themselves. How the public, organizations, and even politicians are using social media is in constant flux. World leaders, fast food brands, and lifestyle influencers are amassing millions of followers and producing a steady stream of content that everyone wants to engage with.
This obviously poses a challenge for recordkeeping.
- How can you capture every like, share, comment, edit, and deletion when every passing minute brings more and more data to collect?
- How will you adapt to platform changes that complicate capture?
- And how can you capture every record before it is deleted or changed?
2. Platform Limitations
Platform limitations are a major challenge for social media recordkeeping because social networks are built for communication and engagement—not compliance, preservation, or legal defensibility.
Social media platforms themselves do not provide tools for compliant, long-term record retention. And they certainly do not make records easy to find or produce in defensible formats for compliance or litigation. A simple data export or screen capture will not satisfy recordkeeping requirements or defensibility standards. Often these data exports are incomplete and do not contain necessary metadata or timestamps.
While users can see visible content, like posts or comments, platforms don’t provide full access to underlying metadata needed to prove the records are authentic.
Worse yet for recordkeeping professionals, every platform’s data export is unique — and therefore inconsistent. This makes organizing and searching the data a nightmare.
Most platforms will not give you unfettered access to your own social media data. To capture content, you likely need API access, which comes with its own limitations. Platforms change or limit their APIs frequently. These APIs require permissions or may be throttled.
Even with API access you may not be able to capture every kind of content, content posted by third-parties. Some platforms restrict access to comments and direct messages.
3. Volume & Variety of Data
The sheer scale and complexity of the content that must be captured and preserved from social media platforms presents huge challenges, and ultimately, compliance and legal risk.
Social media platforms are designed to encourage constant interaction. Posts, replies, retweets, comments, shares, likes, reactions, stories, and reels are published around the clock. One social media account might manage dozens of posts per week, with hundreds or thousands of associated interactions. This flood of content makes manual recordkeeping impossible.
Social media posts can also be short-lived. They can be deleted or edited at any time. Comments and replies can appear and disappear just as quickly. This means critical records can vanish before they’re archived, creating recordkeep gaps.
Social media conversations are also messy and mutli-directional. A single post can spark hundreds of comments, and replies can nest multiple levels deep. This makes it harder to determine what constitutes a record and how to store these conversations in full context.
And of course, social media content can include a wide variety of data types:
- Text
- Images
- Videos
- Live streams
- Polls
- Emojis and GIFs
- Reactions (likes, loves, wows, etc.)
- External links
Each of these must be captured in full, with context, including associated metadata, for the record to be legally defensible.
This variety and volume of data grows exponentially when an organization uses more than one account or social media platform. Each platform has its own, unique data structures, different API access rules, and varying privacy and engagement features.
4. Litigation & eDiscovery Requirements
Social media content is increasingly used as evidence in lawsuits, investigations, and regulatory actions. But capturing and producing social media records for legal purposes is far more complex than just saving a screenshot or copying a post. An organization has to be able to prove the integrity and authenticity of any record provided.
Legal teams and courts expect digital records to be:
- Accurate (reflecting exactly what was posted, when, and by whom)
- Complete (including all associated metadata and context)
- Authentic (verifiable through digital signatures or hash values)
If you can’t provide these, your record might be challenged or dismissed as inadmissible in court.
In a legal matter, certain records must be placed on legal hold—ensuring they aren’t deleted or altered during a case.
But without a sophisticated recordkeeping system, it's painfully hard to identify relevant social media records, flag and preserve them across all platforms and prove you took reasonable steps to comply with discovery rules.
Search and retrieval of social media records during litigation has to be reliable and fast. Locating specific records and exporting them in acceptable formats is impossible using native platform tools or manual exports.
The chain of custody must also be clear. Courts often require you to show records are collected properly, tamper-proof, and stored security.
Social Media and the Information Governance Reference Model
In 2006, the Electronic Discovery Reference Model (EDRM) was created in order to help organizations better understand and manage the eDiscovery process.
The EDRM also attempts to address what’s needed in order to properly manage electronically stored information (ESI) for eDiscovery through the Information Governance Reference Model (IGRM).
Although this model can be immensely useful in managing ESI, there are very specific information governance considerations when it comes to online data like social media content. With this in mind, we’ve expanded on the IGRM to provide a comprehensive step-by-step guide to managing online records. This model breaks the stages of the IGRM down into 10 distinct steps that look like this:
To understand how an information governance framework like the IGRM can be adapted and applied specifically to social media, let’s zoom into the four stages and 10 individual steps.
Create
Collection
Organizations should be leveraging a solution that has API integrations with the specific platforms. This ensures that data is collected in real-time, and that all changes, deletions, and linked content are collected.
Monitor
Data Loss Prevention
There’s always the risk that an employee (or a member of the public) will share sensitive or private information on social media. To prevent this, organizations should have a system in place that notifies administrators when this kind of information is posted.
Policy Compliance
Organizations should have a detailed policy in place that governs the use of social media. Combined with this should be some form of monitoring solution that allows the organization to be alerted when something is posted that does not comply with the policy.
Retain
Legalizing
This process relates to the capturing of data in a way that will make it defensible in a court. This means gathering associated metadata of all electronic records and furnishing them with a timestamp and digital signatures.
Indexing
What differentiates an archive of electronic records from a basic back-up of data is the fact that properly archived records are indexed, meaning that the content is compiled in a way that makes it easy to search.
Archiving
Once information has been captured, part of the maintenance process is placing that data in an archive. It is important to create back-ups of the archive as well. The data should ideally be replicated three times, saved to WORM (Write Once, Read Many) storage, and backed up remotely in the event of a disaster.
Manage
Analysis and Reporting
Once online data has been archived, you can analyze the information and gain valuable insights. From looking at the number of average daily interactions a social media account has to understanding what posts perform best, a large archive of data makes it easier to take a big-picture view of online activity.
Export and Integration
The last thing an organization should want when archiving data is to have it locked into proprietary software that doesn’t allow for the easy export of information. PDF is one popular form of export that should be available, but data should additionally be exportable in WARC format and be ingestible by eDiscovery platforms.
Discovery and Hold
The ability to place a legal hold is another important consideration. Data doesn’t stay in an archive forever. Organizations can be expected to retain official records for anything from three to 10 years, and once that retention period is reached, information is typically deleted. However, if the data is needed for legal purposes, this should be overridden to ensure that evidence isn’t lost.
Dispose
Records Retention
All archived content has a disposition status, and unless something is on legal hold, that status is usually temporary. So as soon as it falls outside the period during which an organization is obligated to keep the information, the data may safely be deleted. Ideally, this process should be automated to ensure that data is never being kept if it’s not needed.
Long-Term Preservation
It is common for large enterprises to want to preserve online data for posterity, usually in a central repository. When the information is transferred in this way, it needs to be done in WARC format. So once again, it’s important that archive data be exportable in WARC.
Compliant Social Media Recordkeeping Solutions
Pagefreezer Social Media Archiving helps enterprises, government agencies, financial institutions, and organizations of all sizes simplify compliant social media recordkeeping. Our automated archiving solutions allow recordkeeping professionals to collect data for compliance and eDiscovery while automating the entire recordkeeping workflow.
Pagefreezer's Social Media Archiving Key Features:
✅ Real-time API-based capture
✅ Support for all major social platforms
✅ Live-like replay of records with their original look and feel
✅ Metadata, timestamps, hash values, and digital signatures
✅ Deleted content tracking
✅ Legal hold, retention scheduling, and tamper-proof storage
✅ Keyword monitoring & alerts
✅ Advanced, full-text search by keyword, accounts, date ranges, and more
✅ Easy, compliant, defensible export options (PDF, CSV, WARC)
