Tag Archive for: building consumer trust

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)

 

Marketing to influencers and advocates is all the rage, fueled by social media. But if you’ve ever developed a consumer campaign with influencers and/or advocates, you know it can be filled with land mines.
Part of that is what inspires advocates and influencers is different. In my last post about Captivation Motivations, I shared with you the secret driver you’ve already heard of behind so many of our snap decisions and just BARELY touched on rewards and lures.

But they’re actually super closely related to what’s behind our fastest decisions to click, like, join, sign up, or buy. If you’ve played an app or computer game, you’ve probably noticed that these games are getting more addictive (eh, em, Candy Crush anyone?). It’s not just better graphics and faster speeds that are making these games addictive, it’s the deeper understanding of what really motivates people to continue playing and one of those is the power of rewards.

I will get to the secret successful games used in a minute, but first, I want to share something else with you. If you’re thinking of running a giveaway, a promotion, or even thinking of starting an app, you want to keep reading. If you’re using digital and social media to market your brand (and I know you are), you’ll want to keep reading. If you’re doing affiliate marketing, you will want to keep reading.  What I’m about to share with you is essential and will ultimately make or break your product or promotion and even marketing relationships with influencers and advocates, including journalists.

 

You Scratch My Back…Carefully.

The last time someone bought you lunch, I bet your parting words were, “It’s on me next time!” You probably said it without asking where you might go or checking your bank account or calendar. You just blurted it out. The truth is, we’re hard-wired to return favors. Think about that for a minute. We are deeply, sincerely uncomfortable when we think we must return a favor. Next time you run a promotion on Facebook, do a test. Ask people to like the page BEFORE entering the contest and compare that to the results if you ask AFTER you’ve given them something, even if it’s just a chance to win. Chances are you’ll find that if you ask AFTERwards, your conversion percentage goes way up, AND those people remain engaged for longer.
This is because lures trigger our sense of reciprocity.

Want to hear an old-school example of this?
Ever received mailing labels from a nonprofit that you didn’t ask for? Did you know that sending mailing labels with a request for a donation has been shown to DOUBLE donations? And guess what? The average donation is way, way more than the value of the labels.
Why? Because reciprocity is a compelling motivation, and it comes with a quirk: what we give for what we receive has very little to do with the financial value of either. You give something, ANYTHING, of some value without placing a value on it, and the reciprocity trigger kicks in. This is the idea behind successful content marketing.

 

Why You Should Never Pay Your Advocates

There’s a lot of discussion today about influencer and advocate marketing. Lures and rewards are different. Lures give without the expectation on the giver’s part of receiving anything in return. That triggers reciprocity by the receiver.
Rewards are given with the expectation of the receiver to get something in exchange, so no sense of reciprocity is triggered.

Rewards (generally) kill reciprocity, but they can create habits if done correctly (like training your dog).
But it’s tough for marketers to get the consistency required to create a habit. Hell, it’s hard to get the consistency required to create a habit in dog; ask anyone who’s tried.

But marketers can more easily create reciprocity, which is an extremely powerful motivation that rewards do not trigger. Here’s the rub though: reciprocity has some limitations too.
If you offered rewards to those who were already advocating for you to do what they were already doing, you’d see that their desire to support you moving forward would be slipping. That’s because offering a reward on contingency (do this 3X/week and receive that reward) for something someone is ALREADY motivated to do, decreases the desire. And unless you understood this motivational fact, you’d probably be left scratching your head about what happened.
Tread lightly with your advocates, because your appreciation can decrease their motivation if you aren’t careful.

This isn’t to say rewards aren’t effective. They can be very effective. “Share this and receive that…” you see it all the time. That’s a reward, not a lure. Again, ask my dogs. They know if they do something, there’s a good chance there’s a treat for them. That’s a reward; they’ve been conditioned to expect it. Rewards can be potent tools for increasing reach. It creates increased reach by those who AREN’T your advocates; depending on your strategy, that can be very important. Just don’t confuse people you give a reward to as an advocate.

Time: The Biggest Reciprocity Trigger

If you’re really interested in triggering reciprocity, then you should probably do two things:
1) get to know your customer really well
2) think beyond monetary lures (discounts, coupons, even product giveaways).

The reasons for this are two-fold:

Our 90% of the brain (the oldest, largest, and most primitive part of our brain) inherently knows that time is more valuable than items. We inherently value experiences (millennials especially) more than items, so although the default is often a coupon or discount, experiences are more highly valued. Receiving an experience from a product or brand increases reciprocity. So if you use an experience as a reward, you can trigger reciprocity. But to offer a highly valued experience, you really have to know your customer. What YOU think your customer values may differ completely from what they actually value. In the last post, we discussed information seeking as a dopamine trigger, which can also be a reward. So can mastery-this is the essence of gamification. Becoming good at something is its reward and the longer we spend on achieving that reward, the more we value it. Again, what your customers value may include inclusion in a tribe, recognition, or status. All these things can be valuable rewards AND lures for brands.

The other thing to understand is that placing a distinct financial value on a lure (or a reward) kinks up the perceived value. Let me give you an example: If I invited you to dinner at my house for a homemade dinner that was wonderful (of course it would be FABULOUS), but then I spent all night talking about how much I spent on buying the ingredients of the dinner, two things would happen. 1) you would view the dinner as a sum of parts rather than its whole value of time, effort, and community, and 2) you probably wouldn’t feel a sense of reciprocity, no matter how fabulous the dinner was. Don’t force your influencers OR your advocates to view your rewards or lures as a sum of parts by involving money too heavily; it kills goodwill AND reciprocity. This is part of the power of consumer PR – it triggers goodwill and reciprocity with journalists. If you’re going to use rewards or lures, remember, make it something the customer values and think about how to make more valuable than money.

Here’s the bottom line: use rewards for influencers and lures for advocates.

Can you think of a time when a marketing strategy with lures or rewards turned you off? Share them with me here or in social media; it’s a fascinating discussion I love hearing about.

About the Captivation Motivations:

The Captivation Motivations are all built around the “other 90%” of our brain. The part of our brain that is the oldest and most developed part of our brain.

I didn’t make up the Captivation Motivations; I’ve simply been studying them and their effects since 2008. I’ve been testing them in my strategies and tactics, reading and writing about them.
These motivations are not some flash-in-the-pan-do-whats-trendy-now strategy, these are strategies that trigger reactions from the oldest part of our brain. Over the last few years, more and more has been understood about these motivations. But one thing is clear: even though these motivations developed in the earliest days of humanity’s survival of the fittest experiences, these motivations are very much alive and well today. What triggers them in the modern world differs from what triggered them in our earliest evolutionary days.

Recently, Google polled 3,000 Americans to find out how they responded to sustainability messaging. As more brands make efforts to become more sustainable or even start any sort of purpose-driven communications,  these four tips will help you communicate purpose-driven messaging effectively. 

Today’s consumers are smarter about messaging. Millennials, the first digitally native generation, are grown-ups, and have their own kids. Gen X (now called Zoomers), see right through greenwashing. They can smell inauthenticity and they actively bristle at brands leveraging purpose-driven messaging to improve their own reputations. And they are right to be skeptical. According to a Google study global survey of top-level executives 59% admitted to overstating — or inaccurately representing — their sustainability activities. Whoa. That’s not a trust-first strategy at all.

So how can well-meaning brands celebrate purpose-driven messaging like sustainability, and awareness days like Earth Day, without alienating their customers?

Communicate Sustainable Efforts with Plain Language

Purpose-driven messaging is nuanced, but sustainability messaging is quite difficult because sometimes an effort to be sustainable has unintended, non-sustainable results. Yet, it’s important to be clear and honest when discussing your company’s efforts.

One way to do this is to share your sustainability goals and roadmap and be candid about your yearly progress. An annual purpose-driven progress report that is open and available on your website allows your customers to come on the journey with you. And explaining how to you took action and the implications helps consumers understand the complications.

Let me tell you a story. Many years ago, I had a client who created disposable compostable plates and utensils. Before we could even get into messaging, I had to take a mini science lesson because compostable can be problematic due to chemicals used to breakdown items like this, yet using products like this is still better than using plastic that ends up in the landfill, right?

Everyone agreed that anything misleading would destroy trust. We landed on a simple outcome everyone can understand: less plastic is better. And this was a fantastic choice because everyone can clearly understand that we have a plastic problem, and it creates an awareness of a bigger issue that the brand is trying to tackle.  Today if I had that client, we would dig deeper and be even more transparent, but this was 2009, and we were barely scratching the surface of how complicated “sustainable” really is to achieve.

Simple is better. Honest is better. Transparent is better. 

 

Celebrate The Accessible

What creates change? From a sustainable messaging standpoint, we’re past awareness. In 2009, Harvard Business Review study found cost is one key reason people don’t adopt sustainable practices. Things like EVs and solar panels are financially inaccessible, to say nothing of the fact that the nations 44 million renters can’t do either of these things.

But what is one thing everyone can do? Reuse. That’s something to celebrate, and it’s accessible to millions of people. Folgers recently did a commercial about reusing its glass jars; I like this because I think it’s on-point to their consumer. The ad incorporated a touch of nostalgia which was effective too. On the flip side, in a recent AdAge podcast, some creatives slightly skewered the video by asking, “What about the plastic lid?” which I think misses the point. The point is: when you remind your customers of the accessible ways they can make a difference, it empowers them.

Focus on small, actionable, concrete actions that you can celebrate alongside your customers. 

Dire Threats Aren’t Effective

“When asked to describe “actions or attitudes that could make people feel bad about their impact on the environment,” many U.S. survey respondents pointed to images of landscapes ruined by trash, fires, or pollution, while some pointed to images of animal suffering.”

Not only does messaging like this put the consumer in a terrible position, it’s disempowering. This kind of messaging is increasingly ineffective because consumers have had it with feeling bad about a gigantic problem that they, as an individual, can’t personally solve alone. And why is the burden even on the consumer all the time anyway? What is the business doing internally?

Instead, focus on positive outcomes. Before and after pictures of rooftop gardens, clean parks, these are all uplifting images that send a positive, impactful message. 

Use Educated Consumers to Your Advantage

Sustainability has become political. It’s that simple. For example, according to Harvard Business Review:

“Republicans were less likely to buy a compact fluorescent light bulb that they knew was more energy-efficient than an incandescent bulb when it was labeled “Protect the Environment” than when that label was missing.”

Most consumers who want a sustainable bulb know incandescent bulbs are more sustainable. But instead of pointing to the environmental benefits, labeling incandescent bulbs as more energy efficient is effective for a wider range of consumers. Everyone can see the benefits of saving energy, whether for sustainability or economic benefit.

Without a plan and consideration for the pitfalls, purpose-driven communication can do more damage than good. For more recommendations, download our Purpose-Driven Guide, which provides an internal roadmap to avoiding the typical challenges of communicating purpose-driven messages.

Bet your starting to think about next year’s social media marketing plan. And as importantly, where will social media marketing fall into the mix? Will there be more? Less? The latest Advertising Trust report from Neilsen may offer some insights to help you in your planning process.

One of the strongest reasons to increase your social media is the the number one source of consumer trust and action isRecommendations from people I know”.  Trust and action are often hand in hand, and we can’t discount the value of trust, but its also hard to measure. However, what creates trust and what creates action can be different. For example, consumers report that humorous ads resonate most with them. We know that humor is a powerful tool, especially in social media. It might be more powerful than cats, dare I say <GASP>. However, humor is rarely what makes people take ACTION.

The action taking piece is the one I’m always most interested in looking at more closely. And its really no surprise that word of mouth leads the pack. Ads on social networks have a lower trust score than they do action score. That’s actually true for several advertising types. With respect to social media, there are two key take aways:
1)  Use social to build trust and be very aware of what motivations exist for taking action.
2) The power of your tribe: when they share what you’ve got, its a more credible source. So be very aware of what and why people share on social. Tribes deeply impact our actions.

Now, the challenge with a report like this is that these results are all self-reported. The challenge with self-reporting is that people don’t always really know why they do what they do. I know, YOU always know why you do what you do. Or do you? Your motivations may not always be clear even to you. That’s why I started Captivation Motivation Training. 

Just remember, what type of message you use impacts trust and action. Decide what you’re trying to establish in every single post. Be purposeful in your social media practice and you’ll find that you can actually be more human.

 

 

 

PS: If you’d like to download the Neilsen Report for yourself: click here