As social media continues to evolve and align itself with many of today's marketing strategies, ethical disclosure along online channels becomes imperative to successful programming.  Since the FTC's updated Guides Concerning the Use of Endorsements and Testimonials in Advertising took effect last December, the industry has continued to struggle for ways of understanding and practicing the new requirements around transparent disclosure.

The Word of Mouth Marketing Association (WOMMA)--having worked closely with the FTC--has answered the call. If you haven't seen this week's release of their "Social Media Marketing Disclosrue Guide," then you're in for a treat. Designed to be incredibly hands-on and helpful, the simple two-page guide provides an overview and examples on how to disclose along a variety of social media platforms.

Hopefully, you find them to be a great resource. In my new role as President of WOMMA, please join me in a discussion around this topic in a webinar held on March 1, 11Am-12PM CST. To register, or learn more, visit www.womma.org.

 

Permalink 1 | TrackBacks (0) |

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
  

WOMMA has been following a very deliberate process to gain membership and industry consensus on these issues.

• 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)
  

Our next steps are to post current guidelines on the Living Ethics blog for feedback and then to issue final recommendations.  Please review all of the following information and go to www.womma.org/ethicsreview to provide any specific suggestions on what would make the direction either clearer or most consistent. 

Key platforms we're covering:

• Blogs/forums
• Video and photo sharing sites
• Social Networks
• Review Sites
• Twitter
• Other forms of user generated content
  
  

Our Guiding Principles:

• 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."
  

Review blog

• 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.
 



Permalink 1 | TrackBacks (0) |

On Monday, I was speaking on a Panel at the NAD Annual Conference in NY.  One of the other panelists was Mary Engle from the FTC.  Just prior to us going on, Mary's colleague, David Vladeck (Director of the FTC's Bureau of Consumer protection) made the announcement that the FTC was going to be unveiling its revised guidelines affecting endorsement and testimonials for advertisers online.  The panel, not surprisingly, became much more lively with the timely news.



History/Implications:

Last updated in 1980, the new changes will better promote full-disclosure between advertisers and endorsers, protecting consumers from deceptive marketing.  Bloggers and celebrities are also affected under the Guide, requiring transparency in endorsements made when material connections are shared.  In other words, if a marketer/brand provides a product or service with the specific intent to receive a positive "review" in return, the endorser must share this relationship with consumers.  Although the Guides aren't official law, deceptive practices will be challenged by the governing FTC Act.


Perspective/Insights:

Beyond my role as President/CEO of Zócalo Group, I've been serving as President-elect of the Word of Mouth Marketing Association (WOMMA) to help brands and partners understand the  best way to understand and follow these proposed Guidelines.  

More information on the ways these new changes will affect how we, as marketers, do business are forthcoming; for now, I wanted to share with you some of my immediate reactions to Mary Engle and David's announcement of the FTC's revised Guides.

• The power, reach and impact of word of mouth marketing and social media is clearly recognized.  Obviously, the market has evolved (particularly in last few years) since the Guidelines were first introduced in 1980 and changes are necessary
• The Guidelines formally reinforce that ethical transparency and disclosure is crucial for marketers and advertisers today; anything less won't be tolerated. 
• The Guidelines look to be very consistent with the preliminary Guidelines that the FTC reviewed a few months ago.  The biggest distinction appears to be more examples that bring different scenarios to life and help marketers understand the FTC's perspective and best practices.
• It's becoming even more crucial for companies to have a formal policy for how they are going to engage online - and how their employees will engage as well.
• Marketers/advertisers are ultimately responsible for adequate disclosure online; however, bloggers (particularly those who are more professional "reviewers") also have responsibility.
• A great deal of discussion has focused around the question, "What is an endorser,  and how does that distinguish them from the average consumer?"  Different rules apply against a formal paid endorser vs. an individual who is simply trying and reporting on a product or service.
• The FTC is particularly sensitive when it comes to advertising, marketing and engaging kids - new education efforts targeting this group are being announced.
• The Guidelines are consistent with the WOMMA guidelines; brands can go to www.womma.org/ethics to get hand- on, practical insights on how the guidelines can be applied.
• My overall sense from both David and Mary from the FTC is that they are working hard to provide clarity, direction, best practices and insights to marketers on the best ways to operate in this new realm.  Guidelines from WOMMA should provide strong support in coming months.
  

Upholding Transparency: Today and Tomorrow

WOMMA will continue to play an active role in helping marketers and consumers understand the FTC's revised guidelines for endorsements and testimonials, with sessions held as early as this week to provide a full analysis of how these changes will impact your business.  Zócalo Group is also a resource for you as we evolve to an even more transparent interaction between marketers and consumers.  Please feel free to contact me with any questions or concerns (312-933-6272).



Permalink 1 | TrackBacks (0) |