The Chicago-based, social marketing industry body has published a refreshed version of guidelines covering product endorsements on Twitter and much more. Stephen Groom analyses and compares with the UK equivalent.
Topic: Social media
Who: Word of Mouth Marketing Association
When: August 2012
Where: Chicago, USA
Law stated as at: 11 September 2012
The Word of Mouth Marketing Association ("WOMMA"), the trade association of the word of mouth and social media marketing industry, published an updated version of its Social Media Marketing Disclosure Guide ("Guide").
Although primarily for US consumption and to help US marketers comply with FTC Guides in this area, given WOMMA's standing in the world social marketing arena, UK social marketers would do well to heed its content and read it in conjunction with the UK's closest equivalent at this time, the IAB/ISBA "Guidelines on the payment for editorial content to promote brands within social media."
The Guide makes various changes have been made to the previous version to take account of changes in technology, platforms and social marketing practices.
Amongst the key responsibilities imposed by the Guide when brand advocates are active in social media are:
1. marketers should put in place a company-wide social media policy that takes the Guide into account;
2. make sure agencies', partners', networks' and suppliers' policies are aligned with the marketer's policy; and
3. make sure that brand advocates, including employees, are educated, monitored and supervised and adequately disclose their relationship with the brand.
The Guide includes sample "best practices" disclosure language for various platforms, including social networks, photo sharing sites like Flickr, Picasa or Pinterest, blogs such as WordPress or Blogger, microblogs like Twitter or Pinterest and curated content like Scoop.it, Storify.com or Paper.Li.
"#spon", "#paid" or "#samp" for Twitter
For Twitter, for example, the Guide recommends, where there is a "material connection," a hashtag like "#spon," "#paid" or "#samp". In the same context, the UK IAB/ISBA Guidelines mention only "#ad" but "#spon" also seems to be recognised in the UK.
In addition, the Guide strongly recommends including a link to on a Twitter profile, close to the testimonial or endorsement, directing readers to a full "Disclosure and Relationship Statement." This should explain how the advocate works with companies when reviewing products and include a list of any conflict of interest that might affect the advocate's credibility.
"Material connection" is helpfully defined as are other expressions used in the Guide such as "Consideration", "Signs of Approval", "Independent Advocate," and "Affiliated Advocate".
The Guide states that for certain types of program, additional disclosures may be needed depending on how these evolve in "complex interconnected social media environments." The Guide then lists no less than fourteen such programs.
"Like gating" creates challenges
These include so-called "Like gating" where the Guide says:
"Rules, terms and required disclosures should be made publicly and not gated behind logins, firewalls or only made available to users who have already approved or accepted these terms."
Another example is "Reasonable monitoring" where the Guide says:
"Brands should be aware of communications by advocates on their behalf with regard to compliance with their stated disclosure policy. If the disclosures do not appear, marketers must employ commercially reasonable efforts to address the situation, which may range from having advocates insert the required disclosures to requesting they pull the content in question. Marketers should also have a policy in place to deal with non-compliant advocates, including "compliance training" for first-time non-disclsoers and possible dismissal for repeat non-disclosers."
Why this matters:
The Guide does not have the force of law but is a useful insight into US social marketing practices as well as an indication of what might also be regarded in the UK as best practice now and maybe soon, minimum requirements.
The Guide can be found here.
The UK equivalent is here.