Global Brands

Social Media Influencers: When To Disclose

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Updated FTC Guidance on Influencer Marketing Disclosure

Updated July 13, 2023

 

The FTC’s job is to preserve consumer trust. When the FTC adds clarity to its regulations, the purpose is usually to make the guidelines more clear, and therefore easier to follow.

This is an important announcement if you use influencer marketing or consumer reviews.

The updated FTC guidance covers:

1) articulating a new principle regarding procuring, suppressing, boosting, organizing, publishing, upvoting, down voting, or editing consumer reviews so as to distort what consumers think of a product; 2) addressing incentivized reviews, reviews by employees and fake negative reviews of a competitor; 3) adding a definition of “clear and conspicuous” and saying that a platform’s built-in disclosure tool might not be an adequate disclosure; 4) changing the definition of “endorsements” to clarify the extent to which it includes fake reviews, virtual influencers, and tags in social media; 5) better explaining the potential liability of advertisers, endorsers, and intermediaries; and 6) highlighting that child-directed advertising is of special concern.

 

 

You can read about the announcement here:

FTC updated guidance on deceptive reviews 

 

May 9, 2017:

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)

 

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How to Decide When Choosing PR, Marketing or Branding Agency?

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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. So how do you decide when choosing a PR, Marketing or 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. 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.

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3 Reasons Every CEO Needs a Ghostwriter

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What do Jack Welch, Stephen R. Covey, and Richard Branson all have in common? Well, besides being some of the best-known business leaders in the world, they’ve all used ghostwriters. Hmmm…could there be a connection between those two things? Almost certainly. Why? Because executives have a lot on their plate, and to stay ahead and run competitive companies, they need to stay at the 100,000-foot level. This elevated perspective often makes executives great thinkers but poor writers. And that’s OK. In fact, it’s expected. As many as 60% of nonfiction books are supported by ghostwriters. Ghostwriters articulate the grand ideas of thought leaders. So what does a ghostwriter do for you and how can executives use a ghostwriter? Consider these 3 reasons every CEO needs a ghostwriter.

CEOs: Publish or Perish

It used to be that only academics were expected to publish ideas, and CEOs were exempt from that expectation; today, CEOs truly need a ghostwriter to fulfill content expectations.

Despite the dearth of content out there, stakeholders from your board, investors, and even customers expect CEOs to lead, and part of leadership today is sharing original thoughts. Now, notice this does not mean that you must post on Instagram every day, and it doesn’t even mean you need to post on LinkedIn every day. It does mean that you must create thoughtful, original content regularly. Good news, a ghostwriter can help you with that. Ghostwriters have two very particular skills: listening and extracting. For ghostwriters to be successful, they sometimes need to ask probing questions and articulate the idea in the originator’s voice. So help your ghostwriter help you. Sit down with them and share ideas, let them see inside your point of view, and your ghostwriter will come up with a consistent stream of ideas from a few hours together.

Watch What You Say: Platform and PR

As a thought leader, publish your ideas consistently. Sometimes that may be on a platform you can control – like your corporate website or even Medium. Which platform you choose will depend on your thought leadership strategy. For example, if the CEO’s job is to secure investment, then Medium.com is a great place to publish, it’s still a Silicon Valley content darling, even after all these years. But if the executive wants to be seen as hip but accessible, perhaps as part of a larger corporate branding initiative, then a Substack newsletter might be more appropriate. If the CEO is creating commentary on something currently in the news, then a contribution to an industry vertical or a national newspaper could be in order. It’s important that the platform strategy be part of the ghostwriter’s process so they can take into account not only the CEO’s voice, but the culturally accepted tone within the platform or outlet.

A ghostwriter can help a CEO decide on platform and tone – just another reason every CEO needs a ghostwriter.

 

Fill Up the Trust Bucket

It’s no secret that CEOs have a spotlight on them like never, as do their companies, this a truly compelling reason why an executive should use a ghostwriter. Over the years, we’ve seen thousands of CEO apologies on almost as many platforms. Not all apologies are created equally and not all crisis responses are the same, each situation is truly different. But, for a CEO who is comfortable with a ghostwriter, an apology can be a much easier, and faster process. Like anything, when there is a relationship, the ghostwriter can be a critical partner to the CEO, and the PR agency tasked with developing a response or apology. Having a trusted ghostwriter not only helps in a crisis, but they may also help reduced the severity of the crisis because the CEO’s thought leadership has lead to increased trust in the CEO and the brand. And nowhere is trust more important than an unpredicted crisis.

 

At Avaans PR, we offer thought leadership programs as part of our bespoke PR programs, but also as a stand-alone option with our thought leadership PR program. We offer this as a stand-alone program because we know every CEO needs a ghostwriter and a strong PR strategy for thought leadership.

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What Is A Hypergrowth Company?

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If there’s a single buzzword that describes what every entrepreneur and investor is chasing right now, it’s “hyper-growth.” Hypergrowth refers to the exponential expansion that certain businesses experience as they quickly go from non-entity to ubiquity in their field. Think Zoom, Uber, Facebook, and many of the other fastest-growing startups you’ve heard of. But while rapid expansion might not seem like a bad problem to have, if you aren’t prepared for it, your business’s growth could collapse just as quickly.

If your company is seeking a hyper-growth model or otherwise finds itself in a period of massive growth, it is imperative that you have a plan in place to prevent your company’s leadership and workers from getting burned out by the challenges of dealing with rapid expansion. Let’s take a closer look at what a hyper-growth company is, and what you can do to ensure that a period of hyper-growth doesn’t end in an equally steep downturn.

What Does Hypergrowth Look Like?

The term hyper-growth first appeared in the Harvard Business Review in 2008. According to the World Economic Forum, compound annual growth rates (CAGR) above 40% define hyper-growth. Hypergrowth is at least double the rate at which a company’s growth can be considered rapid (20% CAGR), which is itself very fast. To put all those numbers In perspective, most medium-sized companies would be thrilled at sustained 10% growth. Hypergrowth usually occurs after the business’s products and services first become available but before the company has fully developed.

Hypergrowth companies are the envy of the business world. Some examples of well-known hyper-growth companies include Amazon, Facebook, Uber, Stripes, and more recently, Zoom, a company whose hyper-growth was fueled by the COVID-19 pandemic.

Entrepreneurs are constantly trying to start the next big hyper-growth business, and venture capitalists are constantly trying to be the first to identify the next big hyper-growth company (and shove cash into its hands).

Although companies like Facebook, Uber, and Amazon all maintained their growth and did not experience a rapid downturn, they are the exception to the rule. The reason why so many hyper-growth businesses fail is because company leadership failed to properly plan for the many challenges inherent to rapid change and wildly increasing demand.

Challenges of A Hypergrowth Business

Companies that deliberately seek hyper-growth often lose money for years as they rapidly grow, snap up competitors, corner markets, and slash the costs of their products to appeal to consumers. It can sometimes be many years before investors in the business finally see a return on their investment.

For instance, Amazon was unprofitable nearly 20 years before it finally starting turning a profit in the middle of the last decade. Investors take a risk by putting their money in potential hyper-growth businesses, and if they do not remain committed to keeping the business afloat through frequent cash infusion, then collapse could be inevitable.

But while the concept of hyper-growth runs counter to a more traditional model of growth, successful hyper-growth businesses can eventually turn into giant corporations that deliver huge, regular profits to investors.

Unsurprisingly, businesses pursuing hyper-growth face certain unique challenges, including:

  • Too much focus on growth – Although prioritizing growth is one of the hallmarks of a hyper-growth business, a company can fail if leadership gets too focused on scaling the business. By focusing too much on revenue growth, you may neglect problems in areas like IT and operations — the areas that ultimately fuel that growth. As the company grows, more money must be spent updating systems to adapt to the business’s increasing size and workforce. While you are focused on growing revenue, you should also focus on scaling other areas of your business to keep pace. Consider your internal communication with employees and utilize internal and external hyper-growth PR strategies to ensure you’re staying focused on emerging trends that may impact your reputation.
  • Overworking employees – Employees at booming businesses may be expected to work long hours, but there can come a point where those workers get burned out — and even startup culture can’t prevent the exhaustion that working 80+ hour weeks can bring. When some employees put in excessive work hours, that signals to other employees that they should do the same, and it’s at that point that hyper-growth business culture can become toxic and unsustainable. Even though many employees may be eager to work exhausting hours because they believe in the company’s vision and business objectives, overwork leads to mental and physical health issues that could hurt the company more than that hard work helps it.
  • Marketing expenses – The bigger your business gets, the more it will cost to market your business effectively. At some point you may need to reevaluate your marketing solutions and determine if there are any lower-cost options. By maintaining exhaustive and meticulous metrics, you’ll be able to track your profit margins appropriately.

The following tips can help you manage a hyper-growth business in a responsible way and ensure that it successfully overcomes the challenges listed above:

  • Strategize – If you are too focused on growth, you may lose sight of other challenges that may obstruct your business’s path to success. Have a solid growth strategy in place, and consider working with a PR firm to develop a plan that serves your business’s best interests. Select a PR firm that has experience working with clients in your specific field, a vast network of industry influencers and experts, a team of creative content developers who understand your target audience, and access to top-level consultants who can help you safely sustain this period of hypergrowth.
  • Focus on culture – A good company culture is what keeps employees committed to your vision and your company’s growth, and attracts the high-quality candidates you’ll need in order to sustain that growth. Ensure that your employees have a healthy work-life balance, and foster camaraderie and friendship among your workers. As you are developing your company’s culture, remember to provide employees with benefits and perks that they actually want and that actually improve their lives. Beer on tap and arcade games in the lobby may seem cool, but they’re a poor substitute for a company that actually cares about its employees as people and fosters a good work-life balance.
  • Don’t forget about profits – Many companies can successfully burn through cash as they fuel rapid growth, but few can turn endless investor patience into a long-term business model. The end goal should always be sustained profits, not eye-popping revenue fueled by even larger losses. Build loyalty and trust with your investors by laying out a future profit plan.

PR for Fast-Growing Companies

If you have more questions about hyper-growth business strategies, contact our PR professionals at Avaans Media today to discuss your business objectives and get to know our team.

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The Dave and Busters Tweet Lesson: Stand By Your Brand

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This week, with the Dave and Busters “Juan” tweet yet another social media gaffe made it’s what into the collective conversation. It sparked furious cries of racism. It sparked snickers. It sparked the “holier than thou” media to earn mega points for traffic.

Imagine for a moment, the alternative tweet: “I hate tacos” said no one ever. #tacotuesday.

Imagine what THAT would have caused: crickets.

Which of those  two messages was more brand consistent, more interesting, more compelling and took more courage?

Branding is like getting a tattoo: it takes guts and commitment.

Tweet: Branding is like getting a tattoo: it takes guts and commitment.

This is why brands and businesses must be crystal clear on who they are, what they stand for and who their target customer is. I’m not suggesting that every brand and business rush to the edge of every cultural controversy and insensitivity in order to create some reaction to their message. But in order to make it interesting they HAVE to know where the line is on risk taking. Brands and businesses have to accept that people who AREN’T their customers aren’t going to “get” it and they have to stand with their customers who DO.  If you insist on completely bland copy, messaging and creative, you will get some bland results.

Tweet: If you insist on completely bland copy, messaging and creative, you will get some bland results.

Tweet: Brands and businesses have to stand with their customers who DO “get it”.

I’m actually disappointed Dave and Busters didn’t fire back to the haters with another pun. Dave and Busters is a GAMING VENUE for grown ups. It isn’t a financial company, it isn’t a children’s nonprofit, it isn’t a government agency, it isn’t a church. It’s supposed to be FUN. Taco Tuesdays are supposed to be FUN. I don’t know about you – but I could use a little fun in my tweet stream.

So here’s where we’re at with a collective lack of spine in the social, marketing and advertising world: be creative, be dynamic, create conversation and excitement, but DO NOT, UNDER ANY CIRCUMSTANCES TAKE RISKS. Does the marketing and advertising world really want to be known as the analysis paralysis industry whose signature color is beige?

Tweet: Does the marketing and advertising world really want to be known as the analysis paralysis industry whose signature color is beige?

Yes, let’s think through things. Yes, let’s consider context. But let’s stop freaking out the minute someone with 2,000 followers takes issue with an edgy statement. Let’s understand our brands, their purpose, their customers and values and let’s stand by those values even when everyone else doesn’t get it. It’s OK. If you’re brand is truly defined, not everyone will.

Yes, the pain of nasty-gram tweets and email is piercing, they don’t last forever, in fact, in most cases, those very same people are off on an entirely different tangent tomorrow.  Being a wishy washy brand isn’t good for anyone, except dish soap – and those consequences are far longer reaching.

Tweet: Being a wishy washy brand isn’t good for anyone, except dish soap – and those consequences are far longer reaching.
Stand tall. Take smart risks. Stand by your customers. Have some brand confidence. Stand by your brand.

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