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The FCA does not require firms to carry out social media screening as part of a fit and proper assessment.
But that does not mean the question has gone away.
As the regulator places more emphasis on integrity, culture and non-financial misconduct, many firms are now asking whether publicly available online behaviour should play a part in how they assess risk.
That is a sensible question. The challenge is answering it in a way that is proportionate, defensible and practical.
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Why online behaviour is now part of the conversation
Professional and personal lives overlap far more than they once did.
People use online platforms to comment on public issues, share opinions, interact with colleagues and build their professional profile. Most of that activity is entirely unproblematic.
But sometimes public online behaviour can raise wider concerns. Harassment, discriminatory views, threats, abusive language or behaviour that creates reputational damage may all become relevant where a firm is assessing integrity and judgement.
That is why social media is now part of the broader fit and proper debate, even if it is not a formal FCA requirement.
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Public information is the key boundary
If firms do decide to consider online behaviour, the starting point has to be clear.
The focus should be on publicly available information only. That means material an individual has chosen to make visible in the public domain, not private accounts, closed conversations or personal communications.
That distinction matters. It helps keep the process proportionate and reduces the risk of firms straying into areas that are harder to justify.
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This should never replace core checks
Social media review is not a substitute for proper screening.
Firms still need the core elements of fit and proper assessment in place: identity verification, employment referencing, criminal record screening and sanctions or PEP checks where relevant.
At most, social media should be treated as an additional source of context. It may help identify something that needs further review or discussion, but it should not become the sole basis for a decision.
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The real risk is inconsistency
For many firms, the bigger issue is not whether they can review social media. It is whether they can do it fairly.
An unstructured approach can create problems quickly. One hiring manager may search extensively while another does nothing. One candidate may be scrutinised more heavily than another. Personal opinion can start to influence what should be an evidence-based process.
That is why any use of social media in screening needs clear guardrails.
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What a balanced approach looks like
If firms choose to include social media within a wider screening framework, the process should be proportionate, consistent and documented.
That means being clear on when the check is used, what kinds of issues are relevant, what sources are in scope and how any findings are reviewed. It also means ensuring that decisions are based on objective evidence rather than personal views or assumptions.
Handled properly, social media review can act as a supplementary indicator of potential risk. Handled poorly, it can introduce subjectivity and inconsistency into an already sensitive process.
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A useful input, not the entire fix
For most firms, the practical answer is not to overstate the role of social media.
It may have value as one input within a broader screening framework, especially where firms are thinking more carefully about conduct, integrity and reputational risk. But it should sit alongside, not instead of, the established checks that underpin fit and proper assessments.
The goal is not to monitor everything a candidate has ever said online. It is to make reasonable, proportionate decisions based on relevant information. That is the standard firms should be aiming for.
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