Ethics

Is Facebook vulnerable?

April 21, 2018 by Susan Getgood Leave a Comment

For the first time since its very early years, Facebook is vulnerable. The Cambridge Analytica mess highlighted an important but oft-overlooked fact about Facebook’s business model. Facebook’s business is data, monetized through advertising, not community or social networking. Social networking and community are merely the means by which it gathers and aggregates data and delivers advertising.

This was easy enough to forget in the feature wars and fight for online social dominance, but the public now is generally far more aware than ever that if you aren’t paying, you are the product. It’s also now clear that Facebook’s business models skirt very close to violating consumer privacy, if not outright violations. When working as designed, by the way, not through some breach or hack into the system.

While Facebook has announced changes in the face of governmental scrutiny in the US and Europe following the Cambridge Analytica revelations, the response still seems pretty superficial. Lipservice, not customer service.

As a result, while I wouldn’t sign a death certificate for the platform any time soon, consumer trust in Facebook has seriously eroded, and it isn’t doing such a terrific job at getting it back. At least so far. I’m not sure they can. So many of the problems are built into the very infrastructure. This leaves an opening for competitors.

Others agree.

When asked by NY Mag whether a new platform could get a seat at the table, Dan McComas, former SVP of product at Reddit, said:

I think it’s absolutely possible, but it takes a couple of major factors. I think a start-up needs to think about the monetization and how it can work with the users instead of against the users. I think they need to figure out the right funding mechanisms and incentive structures that also work toward the users. I think they need to have the right product team in place to focus on users.”

Angel investor and entrepreneur Jason Calcanis has put some skin in the game, announcing via his newsletter this weekend a competition called the LAUNCH Open Book Challenge to find Facebook’s replacement. Seven winners will receive $100K investments from the LAUNCH Incubator. In his newsletter, he stated he is looking to fund a social network that is good for society, that will:

– Respect and protect consumer’s privacy
– Respect and protect our democracy from bad actors
– Respect and protect the truth, by stopping the spread of misinformation
– Not try and manipulate people by making them addicted to the service
– Protect freedom of speech, while curbing abuse (not easy!)”

If you’d like to follow along, or think you might like to enter, details are at openbookchallenge.com. The competition is open to existing projects as well as new ideas/paradigms, but ideas alone are not enough. The main criteria for selecting the semifinalists and the eventual winners will be ability to execute.

Reddit, Snapchat and perennial second place finisher Twitter are also in the hunt, but they may have too much baggage (and their own privacy violations) to prevail.

Something will succeed Facebook. It’s not a matter of IF, only of WHEN. Right now, WHEN feels a whole lot closer than it has before.

Influencer Marketing and Instagram: The peril of quantity over quality – MediaKix’s fake Instagram project

August 15, 2017 by Susan Getgood Leave a Comment

Earlier this month, influencer marketing company MediaKix released How Anyone Can Get Paid To Be An Instagram Influencer With $300 (or Less) Overnight, a project it undertook to prove whether was possible to game the system of influencer engagement on Instagram. In short, how easy is it to create fake Instagram profiles, purchase followers and then get offered sponsored content opportunities by the major influencer marketing platforms?

Turns out, pretty easy, at least for the two profiles the firm created – one focused on beauty, and the other on travel, not coincidentally I am certain, two content areas where Instagram is particularly strong, and the demand high for influencers with scale.

This has spawned a great deal of coverage in the industry trades over the past week, including AdWeek, PR giant Edelman and Digiday. All bemoaning the fact that it is possible to game a social network and artificially inflate followers and engagement.

I’m mostly surprised that anyone IS surprised. The demand for volume, for more, more, more – bigger reach, more likes, more clicks — is bound to lead to both fraud and waste. It did in advertising, in search of the almighty click, and it has in social, in search of likes, comments, shares AND clicks.

Let’s take the two problems separately. Fraud is the intent to deceive by artificially inflating numbers, whether buying followers or engagements. Waste is the natural by-product of scale. Not every legitimate viewer/reader of a message is the target, no matter how good our demographic and behavioral targeting. Even today, with the phenomenal matching made possible by programmatic advertising, there will be waste, and targeting on social is a mixed bag. You can do it within a social platform like Facebook, but not across platforms.

In my opinion, the platforms are responsible for posting the first level of defense against fraud in influencer marketing. The social platforms, to police the activity and manage fraudulent accounts effectively. The influencer platforms, to build similar checks and balances into their technology so brands can trust their influencer recommendations.

Managing the impact of waste, however, is part of the influencer marketing strategy. Our best offense is to put scale in its proper place in the strategy. Quantity – followers, likes, comments, shares, clicks – is not the only metric that matters. Quality of engagement is just as important. In the long run, perhaps more important. That means balancing your strategy, and including tactics that lead to deeper engagements with your current and potential customers as well as broader, more volume-centric microinfluencer tactics.

Remember: the influencer who matters is your customer. Always. That’s why influencer marketing works.

Disclosing sponsored content: Celebrities, Instagram and the FTC

May 26, 2017 by Susan Getgood Leave a Comment

Last month, the FTC sent letters to a bunch of celebrities, reportedly chastising them for improper disclosures. Here’s what this means for marketers and influencers creating sponsored content.

First things first. There are no new FTC Guidelines for Advertising Disclosures. Still the same basic rules we’ve been working with for years:

Disclose material relationships. If an influencer is compensated, whether cash or in-kind, she has a material relationship with the brand.
Clear, conspicuous disclosure in proximity to the endorsement. Unambiguous language. Placed where the consumer will see/hear it when she sees or hears the brand mention, the endorsement.
Accurate. The influencer and the advertiser both have an obligation to strive for accuracy and correct errors.

More details in my FTC Disclosure Guidance deck.

What we did get in April was additional FTC guidance on the disclosures.

FTC guidance typically comes when the agency takes an enforcement action. In this case, it was the 90 letters to various celebrities and celebrity influencers who regularly promote brands using insufficient or unclear disclosures, sent in response to a complaint from watchdog group Public Citizen last Fall.

Generally, FTC guidance focuses on what to NOT do by highlighting practices that it deems insufficient. The FTC does not give an exact blueprint on the right way to disclose a brand relationship. If someone tells you (and I have heard this): “This is the official FTC disclosure,” they do not know what they are talking about. There is no standard, official disclosure. Just guidelines and guidance and the business practices we have developed to comply.

What was in the current guidance? Nothing surprising to those of us that have actually read the guidelines and previous guidance. The only surprising thing was that the agency took the step to reach out to influencers. Typically it focuses on advertiser compliance, for example the Lord & Taylor Instagram dress campaign of March 2015, settled in March 2016.

Here are some of the reasons I think they took the step of addressing influencers directly.

First, letters were sent to celebrities with massive followings. We don’t know exactly who received letters but names in the Public Citizen complaint included David Beckham, Mark Wahlberg, Jenny McCarthy, Chris Pratt and Kendall Jenner. Whether or not celebrities have to disclose has been a source of much confusion, but the test is pretty clear — what will the consumer understand? When the celebrity is in a television or print advertisement, or an athlete is wearing her sponsor’s gear as she performs, the audience has a good understanding of the relationship of the celebrity to the brand. The context tells us. On Instagram, where most of the reported infractions were posted, we have no such context. Everyone is technically, literally technically, the same on Instagram. My posts are viewed by my followers in exactly the same interface as Kim Kardashian West’s view hers. Without disclosure, we don’t know whether the endorsement was sponsored.

Second, the disclosures that folks were using were inadequate. Phrases like “in partnership with” or “my partner,” the hashtag #sp (which has been on record as inadequate for years) and branded hashtags are not sufficient disclosures. Mixing up the disclosure with a bunch of hashtags or putting it at the end of a post where it might not be seen are not sufficient disclosures.

The clearest disclosure on platforms that don’t have character limits is Sponsored Post (or Video or Content), and on platforms that have character limits, #sponsored or #ad. Placed at/near the beginning of the endorsement, especially on posts that truncate on mobile like Instagram. In fact, the FTC was unusually specific when it came to this point, apparently in all the letters:

“…the letters each addressed one point specific to Instagram posts — consumers viewing Instagram posts on mobile devices typically see only the first three lines of a longer post unless they click “more,” which many may not do. The staff’s letters informed recipients that when making endorsements on Instagram, they should disclose any material connection above the “more” button.” (from the FTC press release)

Finally, the problem was spreading. Increasingly, brands are turning to influencers instead of traditional agencies. Especially on Instagram. The longer the FTC let the inadequate disclosures stand, the harder it would be to rein it in. Issuing enforcement letters to celebrities, not just big social influencers, guaranteed a certain amount of media coverage to help the agency get the facts in front of consumers and influencers. In addition to its press release and media outreach, the agency posted the news on both its consumer and BTB blogs.

Bottom line — we are far better off creating amazing content that our audience will love, sponsored and unsponsored alike, than trying to evade the disclosure requirements. Using obscure and inadequate disclosures, especially when there is intent to deceive, betrays the trust of the audience. Don’t do it. It’s not fair to your audience and the FTC is watching.

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In other disclosure news, Facebook has expanded the availability of its branded content tool. ALL Facebook pages that post sponsored content must post it through the branded content tool, which labels the post as PAID. This ensures that sponsored content is adequately disclosed on Facebook even if the organic disclosure is not strong. The branded content tool is currently only available for PAGES. Apply here; turnaround is about 2 days. You no longer have to be verified, and approval to use the branded content tool does NOT mean you are verified (blue check.)

FTC Update: Operation Full Disclosure; Disclosing a compensated trip

October 1, 2014 by Susan Getgood

Last Thursday, the Federal Trade Commission issued a press release about its Operation “Full Disclosure.”

The most important thing for bloggers to know about Operation “Full Disclosure” is that it has NOTHING to do with sponsored posts on blogs. It was aimed squarely at national television and print advertisers that failed to make adequate disclosures in their ads. More than 60 companies received FTC warning letters, largely focusing on disclosures that were in fine print, easy to miss or hard to read.

The FTC Guidelines apply to ALL advertising claims and endorsements – traditional media, social media, even direct word-of-mouth. While its publications and hearings over the past few years have focused on defining and clarifying the guidelines’ impact on social and online media, the FTC clearly hasn’t lost sight of its mandate to protect the consumer from ALL misleading advertising.As the press release clearly summarizes:

“The FTC’s longstanding guidance to companies is that disclosures in their ads should be close to the claims to which they relate – not hidden or buried in unrelated details – and they should appear in a font that is easy to read and in a shade that stands out against the background. Disclosures for television ads should be on the screen long enough to be noticed, read, and understood, and other elements in the ads should not obscure or distract from the disclosures.

The staff letters advised advertisers that to meet the “clear and conspicuous” standard, their disclosures should use clear and unambiguous language and should stand out in the advertising – consumers should be able to notice disclosures easily; they should not have to look for them.”

The purpose of the FTC guidelines is to avoid consumer confusion about advertising messages. By making sure that advertising does not contain misleading statements or hide important facts or conditions, and that any interest, such as compensation or affiliation with a company, an endorser might have in a product she recommends be clearly disclosed.

Store these 3 principal FTC requirements permanently in a room in your mind palace:

Disclosure is required when you are compensated, and you endorse (write or speak about) the entity that compensated you. If you are not compensated, either in cash or goods, there is nothing to disclose.
Claims must be true and the source disclosed (my opinion, scientific research showed…, the company said….)
Disclosures should use clear unambiguous language that stands out and is positioned close to the claim or endorsement.

Speaking of confusion….

There seems to be some confusion in the blogosphere of late as to how the guidelines apply to compensated trips. Here’s my take.

If you are PAID to go on a trip, you must disclose whenever you endorse/write/speak about the entity that compensated you. Compensation can be cash, product or service. In your blog posts. In your tweets and Facebook posts. You write about the sponsor, you disclose you were sponsored.
If part of a compensated assignment includes a certain number of social shares about the experience but not necessarily about the sponsor, and you are asked to use a specific hashtag and/or link to a website for the sponsor, you must disclose. Including the hashtag or link is a promotional activity for which you were compensated.
If you want to tweet about the sunset, or say how tasty the orange juice was at venue that is NOT the sponsor, or whatever, you don’t need to disclose. You are not endorsing the sponsor, so you don’t need a hashtag or a disclosure. Where there is no compensation, no disclosure is required.
That said, if you write an unrelated blog post about elements of the trip that does not include the sponsor, you should still disclose that you were sponsored. Not because the FTC requires it, but because you should give your sponsor the love.
When in doubt err on the side of disclosure.

Here is an example, completely made up.

SuperChic Hotel sponsors you on a trip to the Mexican Riviera. They pay your airfare, comp your hotel, restaurant meals and rental car, and give you an allowance for sightseeing and incidentals. How should you disclose:

Any time you mention SuperChic Hotel, your readers should know you were sponsored. Blog posts, Twitter, Pinterest, Facebook, Instagram, videos. Whatever. Even if you were not specifically compensated for an activity, such as a pinning. Disclose.
Mention the airline, the car rental company, restaurants and boutiques not affiliated with SuperChic Hotel, sightseeing attractions? Unless SuperChic Hotel provided specific instructions on where to go/vendor to use, you do NOT need to disclose a compensated relationship with the vendors. Your relationship is with SuperChic, not with them. That said, as a best practice, I recommend you disclose that your overall trip was sponsored.
Want to tweet about the sand on the beach or the gorgeous sunset. Unless your sponsor is the beach, which is possible, or the sun, which is not, no disclosure required.

This scenario gets a little more complicated if the sponsor is the regional tourist authority, especially if it plans the details of your trip. In that case, I would make the call that anything in the region is supported by the tourist authority, and the relationship should be disclosed with every endorsement. Even the beauty of the beach.

What about a compensated speaking engagement that also pays your way — any or all of fee, comped registration, airfare, hotel? Your presence on the roster of the event is a clear notice of your affiliation with the event. Any reasonable consumer of the conference content understands that you have a relationship with the conference.

The amount of your compensation is not relevant. When it comes to FTC disclosure, it doesn’t matter if it is a liptstick or a Lamborghini; a free lipstick is the same as a car, comped airline ticket or $1000 fee. In my opinion, to double down on disclosure, if you decide to write a glowing post about the conference, or tweet props to the conference organizers, you should disclose your affiliation, but you don’t need to preface every tweet about the conference content with the hashtag #ad unless you were specifically compensated to promote the conference content.

A note about hashtags in social posts: Never use #spon. It is not at all clear. Use #ad or #hosted or #sponsor or #sponsored, and don’t bury the hashtag at the end of your social post. I prefer to see them in context if possible or at the very front of the post if not.

Examples:

Having a great time on trip to Mexico #sponsored by #SuperChic.
Rooms at #sponsor #SuperChic are gorgeous. Now off to the spa.
#ad Don’t miss the regional tasting menu at #SuperChic restaurant

Lastly, a word of advice. The FTC guidelines are pretty simple. Disclosure is required so the consumer of the advertising can put your endorsements in the proper context. It’s common sense — Wouldn’t you want to know if the writer of a glowing blog post about a product you intended to buy was compensated by the company? If it was someone you trusted, you’d still take the advice, but you would want the context of the compensation. The FTC provides guidelines and advice about proper disclosure, and will from time to time go on the record about what it considers inadequate disclosure (like #spon), but it doesn’t dictate a specific way to disclose. When you read articles or blog posts that report that there is a specific, correct way to disclose, take them with the grain of salt. What you are reading is someone’s interpretation of the guidelines cast as an absolute.

FTC Endorsement Guidelines Update: Disclosing a Sweeps or Contest Entry on Social Media

April 1, 2014 by Susan Getgood

Disclosure: Not a lawyer. Don’t play one on the Internet. But I’ve studied the FTC endorsement guidelines. A lot.

Yesterday news broke that the FTC had issued a warning to shoe manufacturer Cole Haan, notifying it that the disclosures used by consumers in its Wandering Sole contest on Pinterest were not sufficiently clear as to the potential material connection between contest entrants and the company. Said the letter (as quoted in MediaPost):

“We do not believe that the “#WanderingSole” hashtag adequately communicated the financial incentive — a material connection — between contestants and Cole Haan,” Mary Engle, FTC associate director for advertising practices, said in a letter sent to the retailer’s attorneys on March 20.

This represents an evolution in the FTC’s thinking with regard to disclosure of a sweepstakes or contest entry. In the early days, it did not explicitly require such a disclosure when a blogger mentioned a brand in a post to enter a sweeps or contest. In part, because there was no material relationship between the parties, so there was nothing to disclose. And, for the most part, back then (2010!), in text-based formats like blogs and Twitter, sweeps and contest entries were often disclosed as part of the entry instructions. Hence no confusion. [Facebook only allowed contest entries on pages recently.]

So what has changed? The endorsement guidelines are grounded in two basic concepts:

is there a material (compensated) relationship between the parties, and
is there a possibility of consumer confusion about the relationship?

In my opinion, the FTC’s thinking has evolved due to the prevalence of contest and sweepstakes entries, particularly on the highly visual Pinterest, that mimic organic endorsements, and do not have clear disclosure that they are a contest or sweepstakes entry. In other words, that the posting is motivated by a commercial incentive, not an organic interest in the product. Quite simply, all these sweeps and contests were causing too much consumer confusion.

The resolution is pretty simple, and follows the same simple guidelines that normal disclosure does. When possible, use natural language to disclose the relationship (Pinned for the Blah Blah Sweepstakes) and use clear hashtags (#sweepsentry) or @ addressing (@BlahSweepsEntry) to make it crystal clear. Using the hashtag or @ addressing is useful even if you also require a natural language disclosure as it makes it easier to track the entries. IMPORTANT: Make the proper disclosure part of the requirements to enter the sweeps or contest.

Why A Marketing Promotion Hashtag Is Not Appropriate FTC Disclosure by Sara Hawkins

Ethics

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