Posts Tagged ‘blogger outreach’
The FTC and New Media: What You Need To Know
The FTC has released a set of proposed new guidelines for endorsements. These are particularly relevant in their application to social media. Several admendments were made that directly refer to new media and the application of these rules in this sphere.
The report is fairly long so I read through it to summarize the main points that are relevant to its application in social media campaigns. If you blog, or are involved in blogger outreach, you should begin following these new guidelines, that way if they are enacted you won’t have to worry.
- If you present an opinion and recommendation to use a product that is an endorsement. Even if you use your own words and present your own views (not use exact messaging from the company) it is still an endorsement.
- Liability for advertisers
- You are liable for false statements made by an endorser (such as a blogger you asked to review a product) so you should be clear on the product details and make sure to convey all the information you have to them. In addition you should check their post for any false or unsubstantiated comments.
- You have to provide full disclosure. The blogger must clearly indicate if there is any material connection (payment or allowing them to keep the product.)
- Liability for endorsers
- As the endorser you’re also liable for your statements. If you write something false or make claims about the product that can’t be proven you’ll be responsible for them as well as the advertiser.
- You must disclose any material connection between the advertiser and the endorser. This responsibility falls on both parties.
This quote from the document sums up the changes related to new media.
New Examples 7, 8, and 9 apply the general principle that material connections between the endorser and the advertiser should be disclosed to several new forms of marketing – blogs, discussion boards, and “street teams.” The Commission specifically seeks comment on these examples, with particular focus on the expectations held by consumers as to the relationships that exist between advertisers and endorsers in these new marketing contexts. The Commission notes in this regard that WOMMA, a trade association whose members are engaged in word-of-mouth and other new types of marketing, stated in its comment that the relationship between endorsers and advertisers should not be concealed, and that the principles of transparency that form the basis of its code of ethics require, among other things, that endorsers not misrepresent their opinions or their identities (for example, by creating artificial entities to endorse products).103 The Commission has long believed that industry self-regulatory codes play an important role in consumer protection, and that the development of ethical standards emphasizing transparency for marketers who engage in new forms of marketing is an important step to this end.
I believe transparency in social media marketing is a key principle to success, and the key point in this quote is just that. From this point on, disclosing all material connections between advertisers and endorsers will be critical. Make it easy on yourself and start now. My thoughts on authentic blogger outreach campaigns are that they should be based on this kind of transparency. You shouldn’t misrepresent paid employees as a consumer and have them recommending (via blogs, comments, forums, Facebook or wherever) people to try your product based on their fake review and experiences. This amendment from the FTC has come about to protect consumers from companies who’ve been practicing these deceptive tactics.
The FTC report includes this example which may help you understand the changes better:
Example 5: A skin care products advertiser participates in a blog advertising service. The service matches up advertisers with bloggers who will promote the advertiser’s products on their personal blogs. The advertiser requests that a blogger try a new body lotion and write a review of the product on her blog. Although the advertiser does not
make any specific claims about the lotion’s ability to cure skin conditions and the blogger does not ask the advertiser whether there is substantiation for the claim, in her review the blogger writes that the lotion cures eczema and recommends the product to her blog readers who suffer from this condition. The advertiser is subject to liability for false or unsubstantiated statements made through the blogger’s endorsement. The blogger also is subject to liability for representations made in the course of her endorsement. The blogger is also liable if she fails to disclose clearly and conspicuously that she is being paid for her services.
For a while new media has been relatively self-policed. However, its adaption by a larger segment of the population added to the borderline deceptive advertising practices that have been utilized in the past have led the FTC to feel the need to step in and regulate our communication here. I firmly support the FTC’s proposed amendments, but I’m concerned on how effectively they’ll be able to enforce them. What do you think? Necessary? Or over regulation? Let’s discuss in the comments.
Photo credit: dbking [Flickr]
The Anti-Case Study: Authentic Blogger Outreach
At #180series yesterday the audience asked our panel an interesting question (via our Uservoice forum):
What are some popular examples of social media gone wrong?
I guess there are some very famous examples of social media snafus – Dominos, MotrinMoms, etc. All classic stories of big brands ignoring the online community until too late and then scrambling to do damage control. But the question got me thinking about social media gone wrong from the other side – small brands trying to use social media to increase awareness and buzz around their products and failing to do so.
“Authentic” Blogger Outreach
A little while back a coworker brought me a proposal [edit: I misrepresented this situation in my original post] that an agency (The Agency) had sent to us as a bid to work on one of our current clients. It was a blogger outreach plan complete with an example of previous work The Agency had done for a client that sold organic juice for children (Juice Client.)
In this case, I’m using the term “blogger outreach” in a very broad sense. The basic premise of the campaign was that The Agency had hired 5-7 people to impersonate blogger personas. These people were very close to the personality type they were taking on, but they were not the actual person. For example, one persona was a “daddy blogger” father of two who was very concerned about diet, organic food and nutrition for his kids (Daddy O.) The person playing Daddy O was also a father and may have cared about diet but was not actually Daddy O. In order to fulfill the “authentic” part of the plan, Daddy O created a fake Facebook account and a few other traces of his personality across the web in case anyone searched for him. Personally, I don’t think that’s very authentic at all.
The process was that Daddy O would search for forums and blogs about health and kids and write some sort of response. He would work in how he bought Juice Client product for his kids and they loved it and since it was also good for them, he was happy. Then he would include a link of course. I clicked on some of the links to his responses that were included in the case study to see examples of this in action. In the ones where his post was still there, it was the first and only post that was ever made under that screen name. When people responded to him he didn’t return and continue the conversation, and when you looked at his profile it was basically a short description of his persona and a link to Juice Client. In the other ones it was clear his post had been deleted.
The one question I keep repeating in my mind as I’m reading and looking through all this is: WHY? Why did you have to make up people? There are so many legitimate (actually authentic) daddy bloggers, mommy bloggers, parent communities, etc that you could have reached out to and gotten real people’s honest opinions on this. And that kind of campaign would have been way more beneficial. Because those people are real, and talk about this stuff all the time, if you’d gotten them hooked on your product they would still be singing its praises right now, whereas the fake bloggers you created are only going to do it on the clock and stop as soon as you quit paying them. No wonder it never took off.
There’s an easy way and a hard way to do things. Taking the time to contact bloggers, send them samples of your juice, ask them to post honest opinions on what they thought about it and disclose that they were sent free juice – That’s the hard way. It takes time, some money, and patience. The easy way gets you links right away, quick results that you can show the client and then end your engagement before they realize that won’t last.
Sometimes the hardest thing is the right thing (pretty sure I stole that from some song somewhere – just can’t place it…) and in this case it really is. Social media is sometimes put forward as an easy, quick thing to do when in reality it’s not. It’s a long term commitment where the pay off isn’t always immediate. We, as agencies, consultants, PR professionals, social media experts (or amateurs), or whatever you call yourself, need to prepare the client for that. It’s our job to explain to them how this works and why they need to take the time to do it right rather than go for the easy, quick win. Let’s all take that responsibility a little more seriously.
Thoughts? Think I’m being too hard on The Agency? Share your opinions in the comments!
Mixed Signal
I have to post an update. In my previous post about the Johnjay and Rich Twitter account I talked a lot about the opportunities they’re missing by using their tweets like messages on a billboard rather than starting a two way dialogue and starting some interaction. I also mentioned hoping that they would read it and contact me. I’m excited to say that only a few hours later I had a message in my Facebook inbox about it, and although they weren’t offering me free concert tickets, they were asking for some more advice. Pretty cool, huh? Love it when brands listen and start convos (active listening at its finest.)
Here’s where I owe them an apology. In my rush to talk about everything they could be doing (and I stand by my suggestions btw – I think they’re pretty good ones), I didnt realize that the account had only been active for about a week. It’s a little too early to have judged the activity on it, for all I know they had planned to implement a few of those same ideas.
Although I may sometimes stick my foot in my mouth, never say that I don’t own up to my mistakes.

