This weekend is the Super Bowl, and while I will be paying slightly more attention to the game because the Patriots are playing, my main interest is in the advertising. This year, I will be watching closely to see how many commercials drive to Facebook pages, in addition to or instead of, a website.

Because Facebook is clearly where so many brands are going these days. It reminds me a little of the “web rush” in the mid/late 90s when mainstream brands realized what many tech companies had grokked since the first browser in 1993, that the browser had changed the marketing equation for good. It was a little like a gigantic penny drop. Suddenly every brand had a website, and URLs were promoted everywhere.

Now it is Facebook. Everywhere. Marketing strategies built around Shares and Likes.

This makes me very nervous. Your marketing strategy should include Facebook. With its user base edging every upward to a billion, you would be foolish to not use the social network in your marketing plan.

BUT, your marketing strategy shouldn’t be a Facebook strategy. No matter how small or large you are, don’t put all your eggs, even just for a single promotion, into one basket.

Especially this basket, over which you have no control. All those fans you are spending so much of your budget acquiring? Your connection with them relies almost entirely on Facebook. Sure, you can sign them up for email lists and such, but the community aspect? That happens on Facebook.

And what Facebook gives, Facebook can taketh away. Not literally of course. But it can change its terms or add fees. I am not saying it will hold your brand hostage, but it could.

So, when you are integrating Facebook into your marketing strategy, think about how you can leverage its benefits while protecting your brand’s assets and consumer goodwill.

Go Patriots!

This is the time of year when some folks trot out the tarot cards and crystal balls, and attempt to predict the coming year. And others wax eloquent (mostly)  on what transpired in the year just past. Over the 7 years I have been writing this blog, I have generally tried to stay away from this sort of post.

This year, however, that is pretty much what you are going to get. There are a few trends that I have been watching for a while now, always intending to post about them but never quite having  the time. Here’s the first.

Facebook  just wants “to be a real boy” and become a social content platform.

Facebook gets lots of eyeballs — 800 million active  worldwide users, 50% of whom access it everyday according to the company’s stats page. And the boys behind Facebook are smart cookies; they know they need to give people a reason to keep coming back. But, it seems like they aren’t entirely sure that catching up with friends and family and sharing “stuff”  is unique and defensible enough. And mining user data only works if you keep the users.

So they’re hitching their horses to the content wagon, and setting themselves up to be a content platform. Brand pages, apps, timelines and other enhancements designed to make Facebook a source of information, not just connection.

Brands are diving right in. Everyone has a Facebook landing page, contest or app. The ubiquitous URL in advertising has given way to the Facebook like and share buttons.

At the end of the day though, the Facebook platform is inherently hostile to robust content development. It was developed for short form messages and social connections, and layering apps and other tools to make it more content friendly doesn’t make it so.

But we’re sure as shootin’ going to try. Facebook has the eyeballs that brands want, and doesn’t want them to go elsewhere.  The more of our activities and transactions it can own, the better that database gets.  In the coming year,  more and more brands will shift content to Facebook that in the “old days”  would have been on brand-owned microsites.

The $25K question is, will they really recognize sufficient benefit from being on the Facebook platform to make up for the inherent unfriendliness of the platform to branding and deep content. Not to mention the murky area of who owns what on Facebook….

The more transactional, ephemeral and social the content, the more successful the efforts will be. Deep thinking? Complex topics? I just don’t see Facebook as a hospitable place for this. The Facebook brand page just doesn’t have enough branding to make the brands happy, or enough information to make the consumer happy. For one thing,  all the custom developed apps bypass one of the key benefits of Facebook, the simple user interface.

Brands will try, but in the end, I think the winning strategy will continue to be to link into the social graph to promote or aggregate content that lives elsewhere on microsites and blogs. This allows the brand to leverage the social aspects of Facebook, but still own their own robust content platforms.

Unfortunately, at the moment, things are moving in another direction,  and 2012 is going to be the year of bigger and splashier brand pages on Facebook.

Fasten your seatbelts. It’s going to be a bumpy night.

Earlier this week, the All Facebook blog reported that contests and promotions on the Facebook platform would no longer need a written pre-approval from Facebook. This removes a significant barrier to entry to hosting a contest on a Facebook Page for smaller organizations.

Under the old rules, promotions required pre-approval, but the only way to get it was to have a designated Facebook rep, and the only way to get one of those was to run $10K of Facebook advertising.

All the other rules remain the same, so you still cannot use status updates as a method of entry  or automatically enter someone for becoming a fan.

Since I joined BlogHer earlier this Fall, I have had a lot going on — traveling, speaking, digging into the new job, moving my family to the NY area — and this poor blog has been sorely neglected. So neglected in fact that my 6th blog anniversary passed earlier this month and I didn’t even notice.

Thinking about that milestone over this holiday weekend led me to think about some of the changes I’ve observed in the blogosphere.

In 2005,  early adopters were dipping their toes into the blogging waters. The hot topic was the corporate blog, and the term “social media”  wasn’t even being used yet — Facebook was in its infancy and Twitter wouldn’t even be invented for another year. Public relations agencies were just beginning to reach out to bloggers on behalf of brands, mostly high tech and consumer electronics. Online conversation often swirled around the mistakes agencies and companies made with poorly targeted “spray and pray” outreach.

Now, according to research conducted by the Center for Marketing Research at UMass Dartmouth,  23 percent of the Fortune 500 have public blogs, including four of the top five corporations (Wal-Mart, Exxon, Chevron and General Electric), 60 percent have corporate Twitter accounts and 56 percent have Facebook pages (The Fortune 500 and Social Media: A Longitudinal Study of Blogging and Twitter Usage by America’s Largest Companies).

The study, which was announced at the Annual Research Symposium and Awards  Gala of the Society for New Communications Research, concludes:

“This [adoption of social media] clearly demonstrates the growing importance of social media in the business world. These large and leading companies drive the American economy and to a large extent the world economy. Their willingness to interact more transparently via these new technologies with their stakeholders is [a] clear. It will be interesting to watch as they expand their adoption of social media tools and connect with their constituents in dramatically new ways.”

Furthermore, according to research conducted by FedEx and Ketchum, and reported in eMarketer, 75 percent of companies worldwide participate in social media in some aspects of their communications and marketing strategy, with 10% actively leading in the space and 15% still mostly on the sidelines observing (Leveraging Best Practices for Social Media).

Another hot topic in the early days of this blog was whether the Securities and Exchange Commission (SEC) would accept blogs as an outlet for material disclosure by public companies.  The SEC began studying the issue in late 2006 and in 2008, announced that it would accept websites and blogs as outlets for material disclosure under certain circumstances.

The topic that has engaged me the most since I dove into the social media pool, however, is the relationship between brands and consumers. Initially, this activity was called blogger relations, a name that reflected its roots in public relations and a focus on blogs. Over the past year or two, the term blogger outreach became more prominent — in part I think in an effort to distance the work from public relations. At least that was my reason for the vocabulary shift.

The sphere of activity also has extended beyond blogs to embrace social networks like Facebook and microblogs like Twitter and Tumblr, and influence is just as important as blog real estate, prompting a shift to talk about  “social media influencers” rather than just bloggers.

Going into the new year, I will be shifting my analysis of this topic to focus on influencer engagement. How well do we engage influencers across the range of social media channels? What can brands do to better engage the customer with the brand premise while retaining authenticity? What is the role of the influencer herself? What can she do to engage proactively with the brands she loves without “selling out?”

Bottom line, I am more interested in the two-way sustainable engagement, brand to influencer and influencer to brand, than I am in a one-way outreach or a single campaign.

Next week, I’ll kick this off with a brief summary of  some best practices for influencer engagement.

This morning, Mom 101 tweeted that a contest that requires “liking” a  Facebook page for entry violates the Facebook Terms of Service, and linked to my post from last January about the new Facebook (FB) contest rules. Her tweet spawned an interesting Twitter stream that made it clear that both companies and bloggers are still unclear about the Facebook contest rules.

Walk this way for some clarity. Keep in mind, I am not a lawyer and do not play one on the interwebs. However, I’m good at parsing legalese, and pretty sure I’ve got the right end of the stick here.

Mom 101 is right and here’s why.

Bottom line, Facebook doesn’t want any explicit involvement in ANY of your contests. It’s all about liability, and the Facebook promo guidelines are designed to distance the social network from whatever companies and bloggers do with their contests.

Facebook’s promo guidelines apply to contests run on the Facebook platform. You are expressly prohibited from using Facebook functionality, including LIKE (formerly becoming a fan), as the mechanism for entering a contest or sweepstakes. Contests run on FB must follow Facebook’s promo guidelines, be approved by FB and use a third party application for the entry mechanism.

You MAY restrict access to the tab where the contest resides on FB to “Likers” (formerly fans) which means someone does have to be a fan to enter on Facebook. HOWEVER, that is different than requiring someone become a fan. Semantics maybe, but it is a distinction that has meaning in law. It’s like the difference between holding a contest for your loyal fans/customers and requiring a “purchase.”  Typically, contests run by big brands also will meet the *legal* requirements for contests and sweepstakes which require an offline/non-purchase mechanism for entry that is publicized as part of the rules.

Further, the promo guidelines say you cannot use language in your contest that requires someone to sign up for Facebook to participate in a promotion. You CAN direct them to a third party application on Facebook, but your promo language cannot stipulate membership. Semantics? Sure. Legally important. You betcha! “No purchase required.”

This example tells us how to interpret use of Fan/Like language in a promo. You cannot use language in a promotion on your blog, site or Facebook page, that asks a person to “like” a page to enter. To Like requires Membership, and use of that language is prohibited under the Terms Of Service (TOS). Facebook does not want its service involved in the administration of your contests. At all.

That the Facebook Like is an extra, optional entry for a contest and the entrant has to submit some other initial entry to qualify? Doesn’t matter. That the entry is actually done by leaving a comment on your blog? Nope, doesn’t matter. The language itself is in violation of the TOS. You are using Facebook functionality as part of your contest and Facebook does NOT want that. I know many bloggers have been relying on this perceived loophole in their blog contests and sweepstakes, but it isn’t a loophole. Don’t kid yourselves.

You can still promote a contest being run OFF Facebook on your Facebook page. That’s promotion, and doesn’t imply Facebook involvement in the running of a contest. Using Facebook’s functionality, however, implies involvement,  and that’s why the network expressly prohibits it.

Advice for Bloggers

If you MUST run contests that involve Facebook, I think you can say something like this:  “If you are a fan of my page on Facebook, let me know in the comments on my blog for an (extra) entry in my contest.” Better though is to leave Facebook activity out of it and just announce your promo. Unless you have the budget to hire a specialist to help you with your contest.

Advice for Companies

Use third party services like Wildfire or Votigo to implement your contest on Facebook and be sure to position it properly:  “We are thrilled to announce this contest for our loyal Facebook fans.”  And feel free to call me. I figure this stuff out for a living, and am sure I am a lot less expensive than a lawsuit.

Disclaimer: I am *not* a lawyer. But I *am* right about this.

UPDATED: Be sure to read the comments. Some folks disagree with my interpretation, and I wrote a pretty long response comment on June 17th. This post was also syndicated on BlogHer and there are a few comments there as well.

This post started out with the intent to be about online privacy and advertising.  I was going to talk about the issues raised at last month’s FTC roundtable on online privacy including behaviorally targeted advertising. Maybe even float around in cloud computing, the topic of next week’s session at the FTC. Talk a little about Facebook’s privacy woes in the aftermath of changing its privacy settings.

But I have bronchitis and a terrible sinus headache, so that post is on hold.

Instead, I am going to have a very  little rant about the demographically targeted ads on Facebook.

Ads like these that pull age related data from my Facebook profile and “fill in the blank” in an otherwise generic ad.

This isn’t targeted advertising.

It’s spam. And it’s lazy.

<Rant off>

In my post earlier this week, I mentioned  Lands’ End’s after-Christmas contest, which let Facebook users enter simply by becoming a fan. I know, because I did it.

Unfortunately, it’s a violation of Facebook’s new promotion guidelines to use “become a fan” as a way for people to  enter a contest. You can require that someone be a fan to enter, but they have to explicitly enter.

I was pleased to see that Lands’ End’s newest contest complies.

Warning – long post

Are social media marketers implementing the new Facebook contest rules and meeting their obligations under FTC guidelines? Survey sez: maybe not, or at least, not yet.

Background

Social media marketing. A bit like the wild west of our imaginations — a little bit glamorous, a little bit dangerous, and as practiced by some, perhaps just a little bit dirty.

At the end of 2009,  however, the Sheriff came to town. Or at least a few parts of it. Facebook’s new rules for contests and sweepstakes were announced in November and updated in December. The revised FTC guidelines for endorsements and testimonials went into effect on December 1.

The landscape is bound to change. In fact, strictly speaking, it should have already. Marketers had plenty of warning about the proposed changes to the FTC guidelines, and their responsibilities under them.

The Facebook changes were more of a surprise but they seem fairly straightforward (and a revenue boon to third-party app developers) although there was a great deal of confusion about whether you could require someone to be a fan to enter a contest. The answer BTW is yes, although you cannot have the action of becoming a fan equal an automatic entry in the contest or sweepstakes. There must be an explicit entry form, and there are very specific rules governing how you can administer the contest on Facebook.

I wondered.

Were marketers informing bloggers of the obligation to disclose when they offered free stuff? The evidence, including that in my own inbox, indicated: not so much. Every so often, I would hear of efforts like Procter & Gamble’s for its Vocalpoint program. They sent an email informing community members of the FTC requirements and telling them how P&G would support them. Not surprising perhaps, given that P&G’s programs and products were cited in more than one news story about the guidelines, but still smart and commendable.

By and large though, it seemed the offers were still coming without any information about the FTC requirements.

On the Facebook front, on Christmas, an email from Lands’ End promoted a contest that one could enter simply by becoming a fan on Facebook. Oops.

Now, I adore Lands’ End, and think their marketing is top notch. If a big brand could make such an error, what about the smaller ones on Facebook? Not to mention all the bloggers who had been running contests to build their fan bases.

It seemed to me that perhaps marketers hadn’t got the message yet. So I decided to do a survey.

Disclaimer: In no way does this survey purport to be scientific or definitive. I just wanted to get a better idea of what was going on in these two areas, and figured a survey would give me access to far more data points that conversations and Twitter chat. It was promoted to my Twitter and Facebook friends and here on the blog, and to Blog with Integrity’s fans, followers and email subscribers. Friends and colleagues kindly retweeted and emailed the link as well. The survey was published on December 27th and closed this morning, January 4th.

Survey Says

Here are the raw results with a little bit of analysis.  Later, I am going to do some cross-tabs and other fancy stuff that SurveyMonkey lets you do when you have to buy a paid account because your responses exceed the 100 you can get with the free account. But not today.

• Started the survey: 243
• Completed the survey: 198 (81.5%)

One to 10 pitches per week was reported by more than half the respondents. The answers to the next two questions were equally compelling. Seventy-percent (70.2%) reported that the number of pitches they receive on average every week had stayed the same since December 1 when the FTC guidelines went into effect, and 63.7% reported that pitches since December 1 contained offers for free products, review products or other compensation.

Seems like business as usual. Time for the money question: Thinking about the pitches you’ve received since December 1 2009 that offered free products or other compensation, *generally speaking* how many have contained guidance or information about a blogger’s obligation to disclose his/her relationship with the company?

It’s cut off in the chart but that orange bar in position one represents nearly 50% reporting that NONE of the pitches contained any information about the obligation to disclose. One of the comments in “other” states that this information did come after the blogger had accepted the offer. Fair enough, but in my opinion, that isn’t soon enough. If we are offering free products or other compensation, we need to state the terms of the deal clearly and up front.

Moving on to Facebook. I asked how often the respondent used Facebook and if they had recently entered any contests.

There are a few interesting things here:

• Most respondents would be classed as fairly or very active users of Facebook.
• The majority of respondents hadn’t recently entered any contests. Is this because fewer contests are now held “on the wall,” they are being held somewhere else (Twitter?), the holidays or some other reason? Questions for a future survey.
• 37.1 % entered by becoming a fan of the page, which is a violation of the new rules.
• Clearly some companies are beginning to implement the new rules, or at least holding their contests appropriately by accident,  with 40 respondents indicating that they entered a contest in a way sanctioned by the new rules.

Demographics

Does this survey prove anything? Yes and no.

No, because it didn’t use a rigorous model. I’d like a more even representation of the blogosphere than “folks who know Susan, Blog with Integrity or Susan’s colleagues,” and I wish I had done a better job on the list of primary topics for the primary blog. If I do another survey, I’ll dig into what people replied for ‘Other’ to make sure I cover more categories.

On the other hand, nearly 200 responses isn’t too shabby. Bottom line, I think these results are a good place to start our exploration of how well — or not — companies are implementing these new rules.

Because like it or not, once the law shows up in town, you gotta live by the rules.

Recently, I’ve become a real fan of Facebook. But while I embrace the possibilities for customers and brands, I haven’t always liked the actions of the company. Walk with me a while down memory lane and my thoughts about Facebook.

Thumbs Up Facebook (7/13/2009)
It’s a beautiful day in the neighborhood (7/7/2009)
My Facebook page experiment (6/17/2009)
The great Facebook URL grab (6/16/2009)
Facebook. The gateway drug to social media (6/4/2009)
What does Facebook want to be when it grows up (11/1/2007)
Ways to grow your business? Piss off the moms? Not. (9/26/2007)

It’s time to make a few deposits in the social media karma bank.

The past few weeks, I have been consumed with Blog with Integrity, my book proposal and getting ready for my vacation to Africa next month. In the process, a number of interesting projects and initiatives from my marketing, PR and social media friends have piled up in my “must blog about that” pile.

Former Bostonian Aaron Strout was kind enough to ask me to be a guest on his podcast, along with Brian Morrissey of AdWeek and Jeremiah Owyang of Forrester, to talk about Facebook Connect. Take a listen. Enteprise web and community managers, you should definitely check out Aaron’s company Powered. They are doing some neat things with enterprise level communities and Facebook Connect.

In my role as an SNCR Fellow, I was privileged to conduct a social media workshop for Goodwill Industries International at their summer national learning conference in Grand Rapids Michigan. The students were great, and really invested in figuring out how to make social media work for their communities. I was already impressed with what the Goodwills were doing with social media, and am looking forward to even greater things in the future.

If you have old clothes and other goods, please consider making the effort to donate them to Goodwill. Your donation doesn’t just fund charitable programs, it funds programs devoted to putting people to work. In these economic times, that literally doubles your money.

My SNCR colleagues Don Bulmer of SAP and Vanessa DiMauro of Leader Networks are conducting a research study called  The New Symbiosis of Professional Networks. They are interested in the the use of social networks as a tool in the enterprise and part of the decision making process. Please check out the website for more information and if you fit the profile, please consider taking the survey.

Janey Bishoff and the team at Bishoff Communications are helping Boston ad exec Jeff Freedman’s non-profit Small Army for  a Cause raise funds for cancer research in memory of Jeff’s late partner Mike Connell. They are holding a fundraising event on September 17th called Be Bold Be Bald!

Participants will wear bald caps on the 17th to raise funds and awareness of a major challenge faced by cancer patients, losing their hair. More information at beboldbebald.org

Chris Brogan’s book Trust Agents: Using the Web to Build Influence, Improve Reputation, and Earn Trust, co-authored with Julien Smith, went on sale at Amazon today to a very positive reception. Congratulations Chris! I promise to read it when things slow down.

Finally the SXSW Panel Picker went live today. Once I sort out all the various panels from friends and colleagues, I’ll let you know. Right now, I’m cross-eyed trying to figure it all out from the tweets. If enough panels from people I know make the cut, I might even make the effort to go this year.