Marketing Roadmaps

Archives for June 2009

More on FTC guidelines and impact on bloggers

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Recently Word of Mouth on NH public radio interviewed Rich Cleland, Assistant Director of the FTC’s Advertising Practices bureau about the revised guidelines on endorsements and testimonials that are expected to be approved this summer. Liz Gumbinner from Cool Mom Picks and Mom-101 provided the blogger’s perspective.

There really wasn’t anything new or unexpected. I’ve written about this topic as has Liz. What was nice was to actually hear it directly from the FTC rather than filtered through another source like AP or BusinessWeek.

Here’s my takeway from the interview:

  • The key issues are disclosure of relationships and truthful opinion. FTC believes truth in advertising/transparency should apply regardless of the media.
  • FTC isn’t regulating whether bloggers take compensation or not. The occasional review or free product is not the issue. FTC is concerned about blog networks, bloggers that consistently receive products/compensation, and disclosure of relationships.
  • FTC believes compliance will be high.
  • Enforcement will be subject to the same criteria as it is now — the extent of the injury will determine whether it justifies the expense of enforcement. I have long believed this would be the case. Nice to hear it from the source.
  • While bloggers would like the FTC to distinguish between free product and cash compensation, it does not seem inclined to do so. However, as noted above, the occasional free product or review isn’t the issue. The FTC is interested in consistent patterns of behavior, and in blog networks, not in whether an individual blogger got a free mascara or a bag of chips.

What they did NOT discuss on Word of Mouth was affiliate marketing, which the AP story said would be included:

“… the guidelines also would cover the broader and common practice of affiliate marketing, in which bloggers and other sites get a commission when someone clicks on a link that leads to a purchase at a retailer. In such cases, merchants also would be responsible for actions by their sales agents – including a network of bloggers.”

I’ve read the initial draft of the changes to the guidelines, and it does not include an example specific to online affiliate marketing such as Amazon. While I expect changes to draft in the final guidelines, I never made the connection between endorsements & testimonials, and affiliate ads like Amazon. Blog networks that offer free products or compensation to bloggers, absolutely. Campaigns that offer compensation to users for reviews on Amazon or iTunes. Again, clearly subject to the guidelines.

But simple affiliate marketing programs?

After much thought and conversation, I don’t think affiliate marketing should be lumped together with the guidelines on endorsements and testimonials. If the FTC wants to review online affiliate marketing practice, it should do so in a separate effort and allow sufficient time for public comment.

Affiliate marketing is a different type of advertising

A review of a product that is compensated in advance by either cash or free product should be considered a form of advertising. The FTC guidelines should apply.

The affiliate marketing relationship is different.

The blogger reviews or mentions a product on her blog and provides a link to a store that carries the item. For example, Amazon. It’s a referral. The blogger is only compensated if the buyer purchases the product from that link.

The explicit endorsement is of the product, although no one would deny that there is also an implicit endorsement of the store, especially if the blog also shows a search widget for the store in its sidebar.

However, once the buyer is at the store, the influence of the initial mention or review is diluted — by the advertising material on the store, by reviews from other consumers, by alternate product suggestions from the store. The blogger’s original opinion becomes one of many sources of information. If the buyer goes ahead and purchases something from the visit created by the affiliate link, the compensation is really nothing more than a “thank you for telling your friends about us.”

Now,  if the blogger received the product for free,  it should be disclosed under the guidelines. But it should be the free product that trips the endorsement guidelines, not the affiliate referral.

Affiliate marketing is understood by Internet users

Whether you see an ad like this:



or embedded links within a post like these Sleep Is for the Weak, The White Trash Mom Handbook, most Internet users  understand these to be affiliate marketing/advertising  links, with a compensation component. Many are probably Amazon affiliates themselves.

In the very long FTC guidelines document, a key condition of the additional disclosure requirement is if the consumer would not otherwise understand that an endorsement was compensated or that the speaker had a material interest. If the consumer would understand that the speech or action was compensated, the public interest does not require additional disclosure.

Examples — An athlete wearing name brand sports apparel is assumed to have a contract with the manufacturer. A celebrity on the red carpet is assumed to have borrowed her gown from a designer. A public figure endorsing a product in a TV commercial didn’t do it for free.

Affiliate advertising on blogs is similar. We don’t need additional information to know there’s compensation. It looks far too much like straightforward online advertising for there to be any real confusion.

What should bloggers do if they have affiliate marketing relationships?

The new FTC  guidelines are due later this summer. We’ll see then how affiliate marketing is covered (or not) in the document. It wasn’t in the initial draft, so we don’t have an example yet.

In the meantime, if you have affiliate marketing relationships, I suggest disclosing them clearly in your blog policy.

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The Amazon affiliate links used above for illustrative purposes are for books written by friends and use the Amazon affiliate account from my personal blog Snapshot Chronicles. So yes, if you buy a book, a friend gets a sale and I get a teeny weeny commission.

Blogger Relations: Where has all the creativity gone?

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There are two principal components of successful outreach strategy. For simplicity’s sake let’s call one Execution and the other Content.

Execution is all the tactical stuff – targeting the appropriate bloggers or reporters, getting the details right — the simple things like name, blog name, email address, following through appropriately, sending review or sample product promptly. Execution is the HOW.

Content. That’s the pitch, the message, the story, the program. Content is the WHY. As in why should I care? Your pitch better answer that simple question straight up, or you will strike out.

Successful outreach programs get both of these elements right. Some recent examples:

No question about it, there are PR and marketing people who really get how to do it right, and are fortunate enough to have clients or bosses who trust them, who let them get it right.

Unfortunately, there aren’t enough of them.

I still see far too many execution errors — the dear blogger, dear xx, sending the same pitch to the same blogger at multiple blogs, forgetting to delete template notes, reforwards of messages without deleting the signature (a recent one had 94 sigs).

Irritating but eventually — hopefully — this will self-correct as tools and training get better and marketers become more sensitive to the potential for stupid, preventable errors. Forming the habit to re-read emails and check attachments before pressing send would be a good start.

The more serious problem is the content.

Agencies are still casting too wide of a net, with too generic a pitch. The lack of creativity is astounding. As is the expectation of what might interest a blogger.

From the inbox:

  • Invitations to promote a contest or support a charity (regardless of whether the blogger has ever expressed any interest in same)
  • The negative competitive pitch. Lead with something negative about the competition and then show how you are so much better. These often are ham-fisted and make the company look like a bully.
  • Requests for the blogger to write about or review a product without an offer to actually send the product. Extra demerits if the blogger asks for product, and the company offers a jpg instead. Or worse, promised product never arrives.
  • My perennial favorite – press releases (especially when they have no cover note)

We also seem far too reliant on BIG programs – trips, free appliances, free consumer electronics. Lately, Twitter seems absolutely cluttered with bloggers announcing yet another giveaway. More More More. Free Free Free.

I’ll leave aside the issues raised by the potential changes to the FTC’s guidelines for commercial endorsements and testimonials.  I think these are manageable, although I do question whether affiliate marketing should be lumped in with commercial endorsements and testimonials. I think not — more next week.

Problems with the BIG blogger relations programs

First and foremost, are they sustainable? One of the phrases that comes to mind is: Begin as you intend to continue. But can they? I think Frigidaire’s current appliance campaign is very clever, but what happens next year?

Another problem is noise. The signal to noise ratio is increasingly out of whack. There are a lot of giveaways and contests announced on Twitter every day, but I’m not sure I could tell you a single brand. It’s becoming a muddle. Full of ethical landmines like companies offering cash to the first 50 reviewers to post about something on iTunes.

Where’s the creativity?

Why aren’t we spending the time to find those commonalities with our customers that create truly memorable campaigns and foster long term relationships. It can be done. We just don’t take the time.

Instead we rely on formulas. For example the tried and true brand ambassador program. There’s NOTHING wrong with a brand ambassador program. Except if the same bloggers get all the invitations to participate, how wide is your message spreading, and what else is it competing with?

Events. Invite x number of bloggers to DisneyWorld or a spa, treat them really well and hope for the best? What are the expectations and are they being met?

And then there’s my favorite – the solution in search of a problem. The latest example is Dunkin’ Donuts’ Dunkin’ Run iPhone app. Sure, it’s cute and clever, but does it solve a real customer problem?

How well do these programs match up to marketing objectives and do they deliver?

The smart folks are measuring. They know when they hit and they know when they miss so they can fix it for next time. In fact, I expect that the good programs I mentioned above  had some form of measurement based on a consumer behavior, not just clip counting or ad equivalency.

This is where we need to place our focus — on developing meaningful relevant campaigns that deliver results.

Relationships are very important, but when you sit down to develop your next program or new business pitch, ask yourself if you are asking the right questions?

Does the program meet the marketing objectives or are you trying to make a favorite tactic fit? Are you going back to the same well, or bloggers,  over and over, because it’s easy, familiar?

This is even more important when outsourcing all or part of a project. You don’t want a cookie cutter program or something developed to meet the goals of another client.

You want a creative program that delivers to YOUR goals.

Do you WANT advertisers to lie to you?

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Today, an AP story about the FTC’s review of the guidelines for testimonials and endorsements and a John Dvorak PC Mag column about same stirred up the blogosphere a wee bit, although the scintillating *yawn* news of Jon & Kate plus 8 minus 1 seemed a potent distraction.

While the spate of coverage leads me to wonder if the FTC is getting closer to announcing the new guidelines — the AP prefers to lead, not lag, the news — nothing was announced today. Apart from the fact that it is officially summer, nothing has changed since the last round of posts and articles on the topic one month ago.

The FTC is reviewing its guidelines on endorsements and testimonials and expects to issue new ones this summer. These guidelines will affect social media and viral marketing. They may also impact affiliate marketing, such as Amazon.

If you are upset about this,  I have some questions for you.

  • Do you want advertisers to lie to you?
  • Do you want to wonder whether a commercial endorsement is honestly from the heart of the writer, or from the keys of a copywriter?

Right. I didn’t think so.

The enforcement guidelines on endorsements and testimonials  exist to make sure that consumers have the information they  need to judge a commercial endorsement. That is the FTC‘s job, to protect consumers .

The Federal Trade Commission is the nation’s consumer protection agency. The FTC’s Bureau of Consumer Protection works For The Consumer to prevent fraud, deception, and unfair business practices in the marketplace. The Bureau:

  • Enhances consumer confidence by enforcing federal laws that protect consumers
  • Empowers consumers with free information to help them exercise their rights and spot and avoid fraud and deception
  • Wants to hear from consumers who want to get information or file a complaint about fraud or identity theft

Consumers.

That’s us.

It’s NOT about the blogger, or your credibility. It’s about whether the reader — the consumer – would have a different impression of your opinion if it were compensated versus unsolicited. Your ethics could be impeccable, your opinion unchanged by the commercial transaction of free product or paid post. It doesn’t matter.

It’s not about you.

It’s all about whether the reader would have a different understanding, and you can’t decide that.

Hence the guidelines, so we can understand our responsibilities under the law, and the need for disclosure.

This doesn’t mean bloggers shouldn’t accept review product or free trips or whatever else companies might be offering for consideration. If you’ve got a property that companies consider valuable, why not profit from it. You just need to understand that under the FTC rules, if you are compensated, either directly or in product, the FTC guidelines for commercial endorsements may apply to you.

I recommend that bloggers publish their review and disclosure policy on their blogs, and if active on social networks like Facebook, Twitter and LinkedIn, a policy that covers your potential activities in these networks. I had updated my blog statements a month ago, but today I added links on Facebook and Twitter to clarify how I might mention products on these status-oriented sites.

Your readers decide if you are credible.

The FTC is just asking that you provide them with all the information they need to make that assessment. That’s everything from what and how you say it, to whether you may have been influenced by others.

You want that from the sites and blogs you visit.

Don’t begrudge it to your audience.

Marketing Roadmaps (and me) around the blogosphere

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I’m testing Social RSS on my Facebook Profile, and need a new post quickly to make sure it posts a new entry to the Wall, so you lucky readers are being treated to a list of places around the blogosphere where I have appeared or contributed in the past couple months. Enjoy!

Diva Talks! Blog Talk Radio podcast. Toby Bloomberg invited Liz Gumbinner (Mom 101, Cool Mom Picks) and me to talk about the best ways to reach out to bloggers. Especially parent bloggers.

Open the Dialogue, MWW Group’s social media blog – Guest post on the differences between bloggers and journalists (May 28) and Interview (June 15th). All about blogger relations, baby.

While you’re over at Open the Dialogue, check out m.insight, MWW’s new mobile app for downloading marketing & pr news feeds right to your phone.

Radical Parenting – Interview.

communicationcontrolling.de – I wrote an article about April’s New Comm Forum for this German online publication.

My Facebook Page Experiment, initial results

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With all the hullaballoo about Facebook Pages, I thought it was time I experimented with one for myself. As I wrote in yesterday’s post, there are a few instances where it may make sense for a blogger to have a Facebook Page. One is for a multi-author blog such as Snapshot Chronicles Roadtrip, the family travel blog I launched about eight weeks ago. Each author can be an admin, use his/her own Facebook following to help build the brand and share the load of adding unique content — beyond just the blog posts that get fed automatically.

I’m still experimenting but I want to warn readers to be very very careful when selecting the initial category for their page. There are three basic categories, each with sub options, and once you’ve selected your choice, there is no going back. The only way to change once you’ve created a page is to START OVER. If you’ve actually published the page and started publicizing it, this means losing those fans, and hoping they follow you.

Why is this so important?
Two reasons. First, discoverability. Facebook uses the categories in search, and if you are in the wrong one, fewer people will find you in general searches, versus specific ones based on your blog or brand name.

Second is that the options under the Info tab are different for each basic category. Local Business allows you to list your physical address, hours of operation, website address and information about parking and public transit. No free-form fields.  For a Brand Product or Organization, you can list typical business information, including company overview and products in free-form fields. Artists, Bands & Public Figures are presented with options very similar to the ones in the personal profile. These cannot be changed or added to.

The Facebook Page for Snapshot Chronicles Roadtrip ended up in the wrong category – Local Other Business. Not because I didn’t pick the one I wanted (Brand, Travel). I did. However, I initially typed my electronic signature with my middle initial; Facebook wanted my Facebook name exactly, without the initial, so it posted an error message. I realized the error, fixed it, and saved.

What I didn’t realize was that in the refresh Facebook had also reset the category to Local  Other Business. I pulled a similar sequence of screens to illustrate this for you.

Initial Screen:

FB1

Signature Error:

FB2

Refresh:

FB3

The good news? I mostly did the fan page to find out what might go wrong when creating one, and lo and behold I was not disappointed. Not having the right options on the Info tab is not a big deal for my family travel blog, but it might be for your company or brand.

What should you do?

  1. Take a look at the three types of pages and pick the right one for your brand, blog or business.
  2. When you are filling out the initial creation screen, check the box, type in your profile name correctly and carefully review the selection of category before you hit Create Page.
  3. If you get the error message, check twice.

You can start over at any time until you actually publish your page, but in my case, I just didn’t notice that the category had defaulted to something else until I started trying to customize the info page much, much later in my process.

I’ll just chalk it up to one of those things I do, so you don’t have to, and hope that my experience helps at least one other person avoid the same mistake. I do know I am not the only one who has run into the problem, as there is a support topic in the Facebook FAQs.

So pick carefully!

Some additional nits:
I wish you could have a different image for the thumbnail and the main graphic. Unlike headshots, which most people use on their personal Facebook profiles, logos don’t always size down to something acceptable in a teeny thumbnail square, and certainly not when the same image is used for both with no resizing possible.

I have a devil of a time getting back to my page to edit it. I hope I am just missing something obvious, but the only way I’ve found so far is to navigate to all the pages I follow and then pick mine. There has to be an easier way….