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Blogger relations

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:

  1. 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.
  2. Claims must be true and the source disclosed (my opinion, scientific research showed…, the company said….)
  3. 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.

Related articles
  • FTC Focuses on Fine Print in ‘Operation Full Disclosure’
  • FTC Endorsement Guidelines Update: Disclosing a Sweeps or Contest Entry on Social Media
  • FTC .Com Disclosures Guidance: What’s new for bloggers and social media influencers
  • Travel blogs, ethics and the FTC endorsement guidelines

Filed Under: Blog with Integrity, Blogger relations, Ethics, FTC Tagged With: FTC

Matching the social platform to the marketing objective

December 31, 2013 by Susan Getgood

Matching the social platform used in a marketing campaign to the marketing objective of the campaign is the first step  of successful strategy. Yet, all too often, early adopters rush to the shiny new object, regardless of whether it is the right choice for the specific need. And on the extreme opposite of the spectrum, risk averse marketers wait. And wait. Until all the proof is in, and any opportunity for first (or even second) mover advantage is lost.

We want to aim for the middle ground – to be in the right place for our audience with the right message at the right time.

Let’s break it down.

Right platform? Consider the social platform in the context of your marketing objectives.  Is the platform conducive to your marketing need?

  • Blogs: The deep content on blogs drives readers through to consideration and often purchase. More than 85% of the BlogHer audience has purchased a product based on a recommendation from a blog (BlogHer Social Media Matters 2012).
  • Pinterest: Its curated content with aspirational and inspirational appeal acts as  long term consideration sets for consumers.
  • Facebook: Personal connections pique interest and foster consideration.
  • Twitter: Broad amplification drives awareness

Drive To Purchase Funnel

The Social Purchasing Funnel
Image Source: BlogHer marketing materials

Right time? Is your audience actively using the social platform? If your customers aren’t actively using a social platform, it doesn’t matter that it is the hot new thing. It is not the hot new thing for your brand. Continue to monitor, but move on, at least for now, for your overall marketing strategy. If you sense potential for the platform, be vigilant for an inflection point – that moment when enough of your audience is actively using the platform for it to be potentially useful in your marketing strategy. Maybe even test it with small pilot projects, but don’t expect any ROI from these pilots other than knowledge about the platform and your customer base. You are asking for failure if you expect your pilot project to deliver significant sales results.

Right message? Is your audience receptive to hearing about or engaging with your brand on this social channel? That they might not want to talk about your product doesn’t mean they might not engage with your company on related topics, but be honest about what you are bringing to the online conversation. Some advice I wrote in 2008 about the secret sauce for a perfect blog pitch might prove useful in this exercise.

You should spend at least as much time thinking about WHAT you want them to say/do, HOW you want them to react and engage with your brand, as you do slicing and dicing the demographics. More really, but I’ll settle for equal time to start. The social platform may be perfect and your audience ready and willing to engage with you, but if your message is forced and inauthentic, it will at best fall flat. At worst, you’ll understand the dark side of “viral” which is far closer to the real world meaning of the word than the sentiment behind the oft-repeated mantra of the social era: <clueless enthusiasm> let’s hope our story goes viral !</clueless enthusiasm>

Spend the time to sanity check your message and your ask, against the audience and the platform, and once you get started, monitor the community reaction closely and adjust as necessary. Spelling your name right is not a good substitute for positive brand awareness and corporate goodwill.

Filed Under: Blogger relations, Influencer Marketing, Social networks, The Marketing Economy

Reviewer’s Retreat 2013 Presentation: 10 Principles for Successful Professional Blogging

July 14, 2013 by Susan Getgood

This version of the 10 Principles presentation includes a section specifically about working with the BlogHer Publishing Network.

Thanks again to all the terrific attendees of Reviewer’s Retreat 2013 for being such an engaged and smart audience.

Filed Under: Blogger relations, Blogging, BlogHer, Professional Blogging For Dummies

What I learned at (Harley-Davidson) Summer Camp

November 20, 2012 by Susan Getgood

Easy Rider Bikes
Replicas of the bikes from Easy Rider on display at the Harley-Davidson Museum in Milwaukee

Note to readers: I have been working on this post for forever. I had it finished one day and the changes didn’t save. Go figure. And then I got busy with work and it just sat in my drafts folder. But here, finally, are my thoughts on Harley-Davidson Summer Camp from a marketing perspective.

I don’t have a life list. Mostly because I never think about it until I am doing something fun or interesting for the first time, and it pops into my head —wow if I had a life list, this would be on it, for sure. But of course by then it is too late — I’ve already done whatever it is. So the life list remains unwritten.

However, learning to ride a motorcycle has been on my unwritten life list for more than a year, so I was beyond delighted to attend the Harley-Davidson Summer Camp as BlogHer’s representative.  At some point, I will get around to writing about the experience, probably next spring when I will actually learn to ride at a Harley Rider’s Edge class. In the interim, I urge you to read the sponsored posts written by my 11 fellow Harley campers.

In this post though I want to focus on three marketing lessons we can learn from this event.

1. Choose your attendees wisely. It goes without saying that you want to be sure the bloggers you invite are interested in the topic, but you also want to have a simpatico group, especially with a smaller event. And you don’t necessarily want everyone to already know each other. After all, it isn’t a reunion, it is a sponsored event.

In the case of the Harley event, some of the bloggers knew each other, but everyone also met a few people for the very first time. It was a well-matched group;  with interests and life experiences in common, but diverse as well. It mixed well, and that contributed to the overall success of the event.

Bottom line, you have to know your bloggers. Obviously, I think we do it very well at BlogHer, and if your blogger outreach or event involves reaching digitally savvy women, I hope you consider working with us. But with time, effort and patience, you can do it too. No shortcuts though. You have to get to know people.

2. Vary the agenda. It is perfectly okay to have brand presentations; your attendees expect to hear from you about your product, are hungry to learn more and take pride in covering the event thoroughly. If they weren’t interested, they wouldn’t have come. But also give them time to experience your product. Granted it is a little easier to come up with experiential ideas when your product is a Harley-Davidson motorcycle and  you can put the bloggers on the bikes as both passengers and nascent riders. And a  museum full of memorabilia is pretty compelling too.

But I think it is possible no matter what your product is. You just have to think a little differently about your assets. The goal is to give your attendees a picture of your brand beyond product attributes and marketing messaging. Here are just some of the things you can do:

  • Demonstrations and trial use (as Harley did) work for nearly every product under the sun, and the more freedom you give the attendees to use the product, the more compelling it will be. In other words, demonstrations good, letting them use it, better and giving them a challenge or task where they can be creative with it, best.
  • Let them meet your employees and other stakeholders, in both formal and informal settings. In my experience, women bloggers are particularly interested in meeting women who work for your company, at all levels. What’s it like to work for you? What was their career path? If you have a good story here, tell it!
  • Your company is part of a physical community and probably active in civic organizations and local charities. Get out of your building and let your attendees meet the organizers and leaders of those groups. Even better, people who have benefited. And best, put them to work somehow. Planting a garden in the local park. Working at a soup kitchen.

3. Mix it up — Part of the incentive for attending sponsored events is the opportunity to meet and hang out with other bloggers. Harley-Davidson did a great job leaving time for socializing in the agenda, among the group and with Harley employees at informal unstructured events like a Milwaukee Brewers game and an evening cruise along the river into Lake Michigan.  The group hit it off so well in fact that we started a Facebook Group so we could still “hang out,” albeit virtually. Some truly free time is also a good idea. It doesn’t have to be a lot, but make sure there is some downtime in the schedule for your attendees to call home and write their blog posts!

What things do you think make a great sponsored event?

Disclosure: As noted in my post, I was hosted by Harley-Davidson during Summer Camp, which I attended in my role as VP Influencer Marketing at BlogHer.

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Filed Under: Blogger relations, Blogging, Community, Travel Tagged With: Harley-Davidson

Lookin’ for Adventure

July 19, 2012 by Susan Getgood

For real!

I was lucky enough to be hosted, along with 11 BlogHer Network bloggers, at a 2 day event at Harley-Davidson headquarters in Milwaukee earlier this week.

Here on Marketing Roadmaps, I will be sharing some observations about the event and the impeccable execution of the Harley-Davidson team. And over on my personal blog Snapshot Chronicles, I will share my personal experiences over the 2 days as well as some amazing tidbits from Harley history. Watch for these posts over the next week or so.

Disclosure: I am a BlogHer employee and attended this event as a representative of BlogHer.

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Filed Under: Blogger relations, Blogging, influencer engagement Tagged With: #harleywomen, Harley-Davidson

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