social media influencer disclosure

Because of continuing conversations with colleagues, brands, and influencers, I wanted to put some guidelines together for based on the FTC’s native advertising guidelines or influencer disclosure.

The FTC has shot some arrows over the bow in the last several years regarding native advertising disclosure, including calling out Warner Bros. and Lord and Taylor.

In both cases, the brand was held liable, not the influencers or content creators, strongly signaling that it’s the brand’s responsibility to ensure disclosure. But, the FTC native advertising guidelines make it clear: ” …the FTC has taken action against other parties who helped create deceptive advertising content – for example, ad agencies and operators of affiliate advertising networks.  Everyone who participates directly or indirectly in creating or presenting native ads should make sure that ads don’t mislead consumers about their commercial nature.”

Basically, no one is off the hook.

As if by magic, the FTC slapped 45 celebrity influencers with warning letters but didn’t forget to include their agents and the brands – in total 90 letters were issued about the FTC native advertising guidelines. It’s safe to say this isn’t going away. It’s always been best practice, but if you didn’t take it seriously before, it’s time to do so now.

My view is this: disclosure and transparency are good for all.

A brand should have no shame about showcasing its products and experiences in a real life scenario. Influencers shouldn’t have shame either, because working with a brand is a badge of honor. It’s a real compliment to a community that a brand values their eyeballs. If you’re ashamed of working with a particular brand or influencer, perhaps you’re working with the wrong partner.

Often times when I have conversations about disclosure with brands and influencers, I get questions like “what if…we do….”

Whether you are a brand or an influencer, if you’re asking questions about how to get around these guidelines, you’re on the wrong track. The guidelines make it very clear: make it obvious to an uneducated viewer that there is a material relationship (basically, anything which might effect the outcome of the endorsement). Influencers are often concerned about “selling out” their community. As an influencer, if you’re making a living from your community with native advertising and you’re not disclosing those relationships, you’re REALLY selling them out.

The Edelman Trust Barometer makes it clear: trust is in crisis. 

Establishing trust and adhering to guidelines is necessary for native advertising and influencer relations to continue. If trust is eroded the FTC guidelines won’t be at fault for the collapse of social native advertising.

So here are the guidelines based on reading hundreds of pages including all of the FTC links provided below.


When do social media influencers need to disclose a relationship with a brand?

Always.

Does this apply to me?

Yes.

Why does it matter?

The FTC says it does.
Consumer trust is important to all of us. 

How do I disclose?

Make it “clear and conspicuous” and leave no doubt.


If you want to read through the FTC’s own words on this:

FTC Native Advertising Guideline Resources

.com Disclosures (2013)

Native Advertising: A Guide For Business

FTC Endorsement Guidelines: What People Are Asking (2015)

The Lord & Taylor Disclosure Case-FTC Blog (2015)

The Warner Bros Disclosure Case-FTC Blog (2015)

Enforcement Policy Statement On Deceptively Formatted Ads (2015)

 

Purpose Driven Public Relations

At Avaans,  we offer those services to our clients, but sometimes we find our clients think they need one thing when what they actually need is another. So what’s the difference and when should you use each as a strategy.

In truth, your business probably needs ongoing campaigns for each of those, but breaking it down helps prioritize when choosing an agency, it helps to know which of the three disciplines (branding, PR, and, marketing) you should select the agency for. Many agencies offer services in all three categories, like Avaans, but most lead with one of the primary disciplines.

When Should I Hire a PR Agency vs. a Marketing Agency vs. a Branding Agency?

What’s the difference between marketing, branding and PR?

Branding: Building Loyalty and Affinity

When to do use it: At brand launch, product launch and throughout the brand’s existence to ensure consistency.
Many people think creating a logo is the extent of branding, but nothing could be further from the truth. Your brand is your company’s personality.

Branding drives the emotional response your audience has to your message and brand. Branding means having a solid understanding of your audience, their emotional triggers. Branding will touch every single thing you do in marketing and PR too. Think about your social media voice – is it sassy or supportive? That’s a branding decision.

B2B firms often think they can skip the branding step, but it’s even more important for B2B brands to invest in clear, concise, industry consistent branding.

A strong brand has a clear voice and gives their customers & clients something they can self-identify with. When your brand fits into their self-story of how they seem themselves you’ll increase affinity and loyalty. The strongest brands have simple identities that rarely change. Think: Coca-Cola (happiness), Apple (innovation) Lady Gaga (acceptance). The strongest brands also always consider their brand when making big decisions (is this consistent with our brand and our customer’s expectations of us?)

All of the below-mentioned tools will support a brand initiative, the biggest key to a branding initiative is to be sure your company has complete clarity on the audience, key messages, and the desired emotional connection. Branding initiatives may include a call to action, but most prominently elicit an emotional reaction or response.

  • Website: with an emphasis design and layout that matches desired emotional response
  • Content: whether 3rd party or branded, designed and selected to enhance brand’s status in the customer’s mind
  • Advertising: with an emphasis on “WHY” the brand is relevant rather than the “how or where”
  • Events: designed with imprint a memorable experience, or attach a brand to a memorable experience, in the customer’s mind, as opposed to a “lead retrieval” strategy

PR: Influence & Social Proof


When to use it: to create awareness, educate consumers, develop trust with stakeholders.
PR is the art of influence and raising awareness. It’s the ultimate in social proof.

In this bucket, we find tactics like:

  • Events: brand-hosted events for customers, community or likely customers
  • Word of Mouth: campaigns that get people talking about your product, brand and key message
  • Media Relations: relationship building with journalists, writers, and bloggers with an emphasis on collaboration
  • Social Media: with an emphasis on key messaging and influencing the market

In PR you may not get editorial control, so don’t count on a strong call to action, although you may get a link or product recommendation, it will rarely come with a heavy sales action. The best PR is earned PR which means it didn’t come with a quid-pro-quo and that’s part of what gives PR enhanced credibility over marketing.

It’s not as if these tactics aren’t supportive of one another (of COURSE you can get leads from PR tactics), but your brand’s maturity, customers, and community will determine your overall mix among other things.

Marketing: Driving Leads

When to use it: after your brand is established and you’ve earned some brand trust.

Acquiring leads is job number 1 for marketing. Depending on your product marketing may also be the science/artform of conversion also.
In this bucket, we find top-of-the-funnel tactics including:

DIGITAL 

  • Website: Landing pages with a strong call to action
  • Content: blogging, lead magnets designed to support the customer’s buying cycle
  • Content: Webinars
  • Social Media: with a link-building and custom content emphasis
  • Email marketing: shopping cart abandonment, new product announcements, customer campaigns and promotions
  • Digital Ads: social ads and banner ads with a strong call to action for potential customers
  • Remarketing: including shopping cart abandonment and past and current customers

IN PERSON

  • Tradeshows/Festivals
  • Seminars

When to use marketing tactics:
Use marketing when your sales people are trained and ready to follow up with leads. Training your sales people to understand the lead source and where the customer is in the decision-making funnel will help increase conversion. Notice one of the key differences between marketing and branding content is the use of a strong call to action.

 

Have more questions about how and when to use these tactics? Get in touch with us.