Travel and Tourism

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)

 

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.

Social Media Is Your Partner in Travel Branding

It’s no secret that today more than ever, digital branding in travel and tourism matters.

According to Google, only 9% of travelers know the brand they want to book with when they start their digital travel search.  This is both an opportunity and a challenge for hotels, airlines and even destinations.

Does this mean consumers have no loyalty? Well, yes and no. It’s well documented that increasingly, people want experiences over things and travelers today lead that trend. Today’s travelers need one of at least two things: a unique experience (for which they will usually pay more) and on-demand information about pricing. It’s more important than ever that your brand is front and center during all phases of research. It also means that your brand needs to reinforce the experience using digital.

Social Media Throughout The Customer Travel Experience

Social media is useful in all phases, but especially the exploratory phase. The exploratory phase is where initial budgets expand as experiences cement themselves. For example, a traveler may be thinking of going to Hawaii, and every airline flies there. But what airlines make the journey even more special? What location has the most unusual once-in-a-lifetime experiences? And how are real people experiencing those experiences? Integrating the day-to-day experience of the visitor on social media helps the travel shopper see themselves in the experience.  Moreover, today’s traveler wants to see a blend of “glossy” travel pictures combined with unfiltered real life.

But it’s more than that. Once the experience is over, what is your brand doing to reinforce their experience? Do you have a program in place which allows them to easily share their experience via social media? Do YOU share their experience back to them? That’s the cementing of brand loyalty and word of mouth almost all travel brands miss. How are you engaging your customers using digital while they are on-site? What can you do to turn complaints into delightful experiences? How can you show you’re engaged with their entire experience?

The other reason this is important is that the mobile experience is front and center. eMarketer predicted that in 2017, mobile bookings would surpass 40% of digital travel sales. Mobile is social and social is mobile. According to Expedia, 27% of Millennials have posted a potential trip on social media to canvas opinions before booking! Obviously, your website needs to be mobile-friendly, but how on-par is your social branding and advertising?

Does it provide a direct experience for booking?

Are you using chatbots on social to improve customer service?

How can you radically improve the investigation and booking phases using digital?

Convenience is exceptionally important to today’s traveler, who have embraced single-site travel booking experiences. BUT, today’s traveler is ALSO looking for boutique experiences, something particularly unique and for that, it’s almost better if it isn’t on a single-site because it gives the air of uniqueness. So balancing the booking trends with experience demand is important, and social media leads in this regard, because you have the change to meet the consumer where they are.

Millennials Don’t “Own” Social Media Travel

These technologies, like chatbots and mobile-friendly booking, are no longer for just the largest brands. They accessible and important for today’s traveler of all ages. It’s easy to think only “millennial” travelers are using these tools, but it’s simply not true. Consider that GenX’ers are in their mid-to-late forties already and their perfectly comfortable on Instagram and Facebook as well. According to Nielsen, Adults 35 to 49 were found to spend an average of 6 hours 58 minutes a week on social media networks, compared with 6 hours 19 minutes for the younger group.

If you’re looking to engage your potential and current audience in social media and digital branding for travelers, please contact us. We have ideas and most importantly the resources, to step up your digital travel branding in every phase of the experience.

Social advertising is here to stay, but with all the options available many brands don’t feel comfortable with the many options, formats, and platforms available. For travel, tourism and lifestyle brands, social advertising is the pre-eminent form of advertising because it so brilliantly works with your customer funnel, your PR and your branding.

If this sounds like you, please keep reading. If you’re feeling 100% in control of such questions such as how much you should spend, how exactly to target your audience and what format makes the most sense for you then I’ll save you some time, you don’t need this blog post.

How much should I spend on social advertising?

Without a doubt, this is the most common question we encounter.

Every business starts with answering this question with a clear understanding of the Lifetime Value (LTV) of customers. A good rule of thumb is your ad buy should be a 3:1  LTV: Cost to Aquire over a 12 month period. For luxury brands or boutique brands that ratio may vary, slightly, but that’s a good rule of thumb.

The next question is “what will I get for this spend?” Again, an absolutely fair question and we have a process for determining this and ways to maximize your spend.

In social advertising, especially Facebook advertising, it’s exceptionally important that you’re clear on your objectives.  Is your objective awareness of recent PR?  Perhaps you’re announcing a new luxury service and want to increase reservations. We can help you identify the most effective objectives for your budget and optimize your ad spend. It’s also very important that your social ads match the customer journey, that’s one of the advantages of social advertising.

How to target your social advertising audience?

All digital advertising includes remarketing tactics, but social advertising also includes very sophisticated other ways to target and this data gets incredibly insightful when using Google Analytics to identify existing web traffic. That’s one small tactic that saves time.

Using all the existing digital data at our disposal is important. Social advertising audiences can even target competitors’ potential customers. There’s an endless number of ways to target audiences, and this is the rub, because frankly, from junk audiences come junk results. Your audiences should also match the ad’s destination for customer phase. For example, there’s no use sending a cold audience direct to a sell page, people unfamiliar with your brand will rarely purchase immediately. Spending time allowing your audiences to get to know you and your place in their lives will save you thousands in acquisition costs, but selecting the right audience for this message is paramount and then how to follow up those ads as the customer moves through the funnel is equally important.

Where should you place your ads?

Even once you narrow it down to a platform or two, in the case of Facebook, there is an overwhelming number of ad placement choices. Understanding the pros and cons of each is important, but even more important is understanding how each of those placements matches your objectives. There are no inherently bad ad placements, only bad ad strategies.

What do I do with all this brand content?

It wasn’t too long ago that obtaining organic reach on social media wasn’t that difficult. Today, the algorithms of (at least two) social media platforms throttle organic reach. Much has been written about that, but the real issue is what to do with your social posts? Are Page Like ads useful? When do I boost a post? Can Instagram drive traffic to my website? All these questions are absolutely relevant and your answer will be based on your strategies and KPIs. There are times where we make recommendations about KPIs that are more current to today’s ad choices and social media atmosphere, then there are times where we can help you match your existing KPIs to perfectly great ad strategies. Don’t forget that there are ways to supercharge your organic content by including user-generated content and well-earned PR. Today it’s more important than ever to integrate all your efforts into your social advertising spend.

Besides social media advertising, what are my options?

Look, with very few exceptions, social media advertising is part of a modern, healthy advertising strategy. Are there other organic options? Absolutely, and they’re probably important to evaluate as part of your marketing strategy. Creating branded content, on your platforms and on existing social media platforms, isn’t “out,” it’s simply changed.

If you’re interested in an evaluation of your expected social media advertising results, email us for a free social media audit. 

Imagine your advertising and marketing becoming 2X more effective overnight. Using emotions in marketing and branding is the key to more effective campaigns

According to Roger Dooley, emotional ads work TWICE as well as rational ads. So it’s important your campaign incorporates emotion from the start. You can deploy these emotions through copy and creative in all formats, analog and digital.

Before you create your next campaign, check in with these powerful emotions in marketing and branding.  Be sure you’ve considered your strategy, both long and short term before deciding which emotion works best in your marketing.

Fear
Fear comes in many forms, and it creates a sense of urgency.

Fear also heightens any other emotion created alongside it and it drives us to make deeper connections with those we share the fear with-this is why scary movies create deepen relationships. 

There are several different kinds of fear, but two common types include:
“Fear Of Missing Out” (FOMO): This particular fear tends to work well on younger people in social media. This works particularly well for items with time sensitivity.
“Fear of Isolation”: closely connected to FOMO, fear of isolation, used in connection with health products, deodorant for example: “use this so you don’t smell, because when you smell, you become a social pariah.”

When to Use Fear in Emotional Marketing/Branding:

  • To drive leads
  • You have a specific and actionable solution
  • You have an easy, no stress way to buy

Happiness/Joy
What happens when we feel happy? You might be surprised.

It’s a fine line because if we’re too happy, we might not be motivated to purchase. But happiness DOES make us want to share. It seems good news travels fast. According to a study by Fractl these are the Top 5 emotions which drive viral content:

  • Amusement
  • Interest
  • Surprise
  • Happiness
  • Delight

When to Use Happiness in

in Emotional Marketing/Branding:

  • You want others to share your message
  • You want to build trust and loyalty
  • You can commit to happy content as a brand

Inclusion

One of our oldest motivations is the need to be part of a tribe, included in a group. For our earliest ancestors, it was a requirement for survival, today, that need is still a powerful motivator and when we have it, we feel safe which leads to loyalty.

When to Use Inclusion in

in Emotional Marketing/Branding

  • To attract or retain customers
  • When you can also utilize the fear of missing out
  • When you have the processes and platforms to create and sustain community

Anticipation

We’re hardwired to anticipate outcomes. We’re not always right, but we are always anticipating. You can use anticipation in a couple of different ways, to attract and retain customers.

Attracting customers with anticipation typically comes with a stimuli and an outcome. The faster the outcome, the more likely we are to repeat the stimuli. Once we’re hooked on the stimuli, the outcome frequency can become variable (you might have learned about Pavlov’s dog, this is the same theory). Gamification uses anticipation brilliantly.

Keeping customers with anticipation requires a product commitment (free sample with every order) or an anticipation experience connected to the product (why subscription boxes are so popular). You can create variables in the anticipation (products, frequency) that will actually heighten the anticipation.

Something else about anticipation: it DECREASES when we’re stressed and change can be stressful. This is why consistency in branding is so very important and why big changes for big brands are big-time risks. Can you think of a brand whose big change created major negative upheaval for them?

When to Use Anticipation in

in Emotional Marketing/Branding:

  • You have the willingness to keep the anticipation fresh
  • You want to build loyalty and repeat buyers
  • Your brand is elevated and/or lifestyle oriented

Expertise/Leadership

Making your customer feel like they’re the smartest/sexiest/most influential is a great way to get people’s attention. People love to be the most “something” of their friends and people will work to achieve this effect.

This marketing emotion is closely connected with our need for mastery and our innate value of time. Because of these two addition motivations, the harder you make it the more committed they will become to the process. It’s all about our emotional triggers again, we’re hardwired to commit more time to something we’ve already committed time to – this is the same theory behind the test drive and keeping you at the dealership during a car purchase.

Again, games do this quite well. Successful fitness trainers do this quite well.

When to Use Expertise and Leadership in your Marketing/Branding

  • When you have a unique process people can move through and see improvement
  • As a relationship builder, such as influencer marketing or tips and tricks your customers can use

Good luck and I look forward to hearing how you’re using emotion in your marketing and branding.