As most of you know, WOMMA has helped shape and lead the charge for effective and meaningful social media disclosure. The recently introduced FTC Guidelines, in fact, make numerous positive references to WOMMA's Ethics Code.As a next step in the process, WOMMA is working to finalize the explicit best practices for social media disclosure for both marketers and bloggers* (like the FTC, WOMMA applies the term "bloggers" to refer to individual posting online content, whatever the channel).
Our goals: Facilitate dialog around and provide explicit recommendations around:
- Where and how marketers can effectively and transparently disclose -- and be in compliance with FTC Guidelines
- Where and how "bloggers" can effectively and transparently disclose -- and be in compliance with FTC Guidelines
- Began dialog at 2008 WOMMA Summit
- Convened expert panel on transparency and disclosure
- Facilitated discussion on "Living Ethics" blog
- Drafted preliminary disclosure guidelines
- Reviewed preliminary disclosure guidelines at 2009 WOMMA Summit (November 20)
Key platforms we're covering:
- Blogs/forums
- Video and photo sharing sites
- Social Networks
- Review Sites
- Other forms of user generated content
- Disclosure must be clear and conspicuous
- Language must be unambiguous
- Considerations must be given to targeted consumers• Disclosure must appear "above the fold."
Marketers' responsibilities:
- Educate "bloggers" regarding responsibilities
- Educate internal corporate audiences regarding responsibilities: create a "culture of compliance"
- Require disclosure from "bloggers"
- Monitor to ensure disclosure is happening
"Blogger" Responsibilities
- Confirm understanding of responsibilities with marketers
- Disclose all material connections
- Communicate proactively with marketer to demonstrate compliance
Best practices for: Blog Disclosure:
Editorial blog
- Disclose any product, service or compensation provided by a marketer
- Disclosure requirement:
- As part of editorial copy
- "I received ____ from (company X) as a sample, to review, etc."
- Disclose any product, service or compensation provided by a marketer
- Disclosure requirements:
- As part of editorial copy
- "I received (X product or service) from (company X) to review"
- "I was paid by (company X) to review"
- Create "Disclosure and Relationships" section on web site
Best practices for: Video Sharing Sites
- Disclosure options:
- As part of video content
- "I received (X product or service) from (company X) to review/create this video
- "I was paid by (company X) to review/create this video"
- As part of video description
Best practices for: Photo Sharing Sites
- Disclosure requirement:
- As part of photo description
- "I received (X product or service) from (company X) to create this
- "I was paid by (company X) to create this"
Best practices for: Social Networks
- Disclosure options:
- As part of photo or video description (see photo and video sharing sites best practices)
- As part of status update
- "I received (X product or service from (company X)
- "I was paid by (company X)
- Create "Disclosures and Relationships" section on profile
Best practices for: Review Sites
- Disclose any product, service or compensation provided by a marketer
- Disclosure requirements:
- As part of editorial copy
- "I received (X product or service) from (company X) to review"
- I was paid by (company X) to review"
- Create "Disclosure and Relationship" section on profile of website
Best practices for: Twitter
- Disclosure requirement:
- Must clearly state hash tag within tweet
- #spon or #paid
- Create link to "Disclosures and Relationships" section on profile
Feedback on this topic and the specific requirements for transparent disclosure online is requested and encouraged as we continue to make this process as clear as possible.





