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Blogger relations

FTC Update: Operation Full Disclosure; Disclosing a compensated trip

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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.

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Matching the social platform to the marketing objective

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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.

What I learned at (Harley-Davidson) Summer Camp

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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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Lookin’ for Adventure

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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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The blog contest you are so glad wasn’t yours…

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Last week, a blogging hot mess developed around a contest being run for Chrysler by Ignite Social Media. You can get the deets at this post by Avitable. Fair warning: Avitable has a definite point of view on the events in question. I don’t.  Or more accurately, I’m not picking a side because I think both “sides” could have done things differently and achieved a far different outcome.

As many on the comment thread on Avitable pointed out, this sort of contest, in which consumers are encouraged to vote for their favorite bloggers so one of the bloggers can win a tremendous prize, nearly always turns into a popularity contest, rife with accusations of gaming the system and so on. Quite simply, they bring out the worst in human nature. Even when there isn’t a “confusion” about the rules.

My advice: stay away from this sort of event. No matter how good it sounds in the brainstorming session. There is a reason why we have election law and elaborate protections to prevent voter fraud, hanging chads notwithstanding. Unless you can prevent fraud, or even the hint of it, do something else with your marketing dollars.

And the truly sad thing? For those guarding the castle gates from the social media juggernaut, the whole mess is evidence that the blogosphere is a dangerous place for brands. No matter who was or was not at fault, the Chrysler brand has been tarnished by association with the whole thing. Even if they don’t  pull back from social media now, others will, and that’s a missed opportunity all around.

Should you work for free?

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The social media “industry” is built on the back of people doing “stuff” for free. The business models of most social networks — Twitter, Facebook, Foursquare, Flickr, YouTube etc. etc. — depend on consumers using the free/”freemium” services and thereby creating both the free content that attracts and retains users, and more importantly, a mine-able database. People. Topics. Linkages (who are your friends, what do you like, where do you go). Marketing gold. And the companies are reaping the benefits of our “work” in potentially ginormous valuations, as discussed in this Businessweek article.

You could argue that posting on Facebook or sending a tweet isn’t work per se. We, the users, are getting something in exchange for our activity — the use of the network to accomplish a personal objective. The question is whether the value is balanced — are we getting enough from our participation in exchange for the value we are helping these companies build?

Honestly, that’s a question that each person must answer for themselves. Participating on Facebook DOES mean that you are surrendering some of your personal privacy, and a great deal of personal information that is going to be aggregated, analyzed, mined and sold. Every Facebook item you post, link or share is going to earn money for Facebook and its investors somehow. Maybe ad revenue. Maybe data mining revenue. But certainly revenue. Facebook is a business, not a public service.

Is it worth it to you? If yes, play away. If not, don’t.

And of course, you can figure out ways to monetize YOUR participation in the networks. Use them to promote your business. Or yourself. It’s all about extracting the value you require from your participation.

The other “work for free” model prevalent in the social media space is influencer relations, which owes its structure to the earned media model inherited from public relations. I’ve written about this before — Is earned media an anachronism?

In a nutshell, the idea is that companies and brands can have such compelling stories that consumers will write about them, share them on their social networks, for free, without compensation. And you know, sometimes that’s true.

Sometimes a product is so compelling that we are happy to harness our word of mouth for no other reason than we love the product. Perhaps Apple products are the only ones that can generate widespread mass word of mouth at the mere whisper of a new version, but we all have things we love that we’re happy to share just because we love them.

I’ll use myself as an example. Recently I bought a SpotBot Pet, a little spot carpet cleaner from Bissell that I first learned about at the BlogPaws conference. It is TERRIFIC, and eventually I will get around to posting a review on my personal blog.

But… products we are intrinsically passionate about are few and far between. Certainly far fewer than the number of firms reaching out to bloggers asking them to work for free on behalf of the brand. To write about a new product. Or attend an event and tweet it up. And so on.

So here’s where I draw the line. If it is work — if you are asked to do a specific thing in a specific fashion or to a deadline — you should be compensated for your time and expertise. Because if you are not paid for your work, it is volunteer work, and if you are going to volunteer for something, it should be something that you care about personally and passionately. I’m pretty sure cereal and motor oil don’t qualify. At least for most of us.

Is a free product adequate compensation? In my opinion, it all depends on what you are being asked to do. Try the product and participate in a short survey? Or leave a comment on a Facebook page? Probably yes. Try the product and write a 500 word blog review? Unless it is use of a car for a year or some other equally large “in kind,” probably not. It’s your call, but remember that the FTC and the IRS do not distinguish between cash and “in kind” compensation. You get a free product, you must disclose, and if you get enough of them, you probably should be reporting the “income” on your taxes. Disclaimer: not a lawyer, not an accountant, consult yours if you have questions about your legal obligations, especially for taxes, which unlike the FTC guidelines, DO have defined penalties for getting it wrong.

So, if you are working in exchange for free product, whatever it is, best to make sure it is something you actually want. Because you may have to pay taxes on it. If it is not something you need or want, cashy money probably would be more useful.

A final point on working for free. I am not saying you shouldn’t volunteer your time, skills or blog content to causes — or even brands — that you care about and want to support. Everyone has to make their own decision on that score. However, if you do work for free, if you give it away, don’t expect the recipient to turn around in future and say, wow, you are so great I should be paying you. Volunteering in the hopes of a paying gig is a losing proposition. It is VERY unlikely to happen.

So when someone asks if they could just pick your brain, or could you just post about this thing on this day and include the following three points, or whatever, understand that you have just created a non-paying customer. And no one can afford too many of those.

Finallly, there’s a fine distinction that I don’t want you to miss. Doing something of your own volition — whether writing a blog, sharing a link or posting on Facebook — is very different than working to someone else’s specifications or timeline. Sometimes it is hard to tell the difference when the email box is overflowing with “opportunities.” All I can advise is to consider the value to both parties in the exchange. If it is an even exchange of value, if you are getting what you need to make it worth it (whether cash, products, connections or feeling good about helping out) and so is the other party, go for it.

If not, you may just want to say no.

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Disclosure: I work for BlogHer. We pay the bloggers who write for us.

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Lessons to be learned from ConAgra/Ketchum’s Sotto Terra blogger event

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I’m back! You had to know I would not be able to resist commenting on the ConAgra/Ketchum “Sotto Terra” blogger events in New York last month that went so horribly, tragically wrong. So wrong that the fallout made it to the pages of the New York Times. Ouch.

I’m not going to rehash the details here, because this post is not about piling it on. The company, brand and agency have been thoroughly schooled in the blogosphere already. Instead, I am going to focus on a few lessons that have nothing to do with the specific brand, that anyone involved in blogger outreach can learn from.

However, this post will make more sense if you know the basics about the ConAgra program. Short version: blogger event in New York. Promoted as an exclusive opportunity to experience a chef-prepared meal. On the day, entree and dessert revealed to be frozen meals. Ooops.

For more details,  please take a moment to read the NYT article and the links below to read the blog fallout after the event.

Lesson Number 1: Don’t fall so in love with your great, clever idea that you can’t see its flaws. Every idea has flaws; every message, detractors. You have got to be willing to be your own devil’s advocate. Ask yourself — what can go wrong? Where can this idea fail? Who might not like our idea and why?  I’m not saying be Debbie Downer on your own creativity. I am however advising you to think it through. Understand that there will ALWAYS be someone who doesn’t like your concept. The question is, are they outliers or your target? If your target audience ain’t gonna like it, don’t do it. That’s what happened with MotrinMoms a few years ago, and it’s clearly part of what happened here.

Poke holes in your own idea. Better you than a bunch of bloggers and the New York Times.

Lesson Number 2: People don’t like surprises. Especially when they make them feel foolish. Think about it. If you are old enough to remember Candid Camera, you’ll know what I mean. The audience of the stunts enjoyed them. The victim, not so much.

More proof? Ever read the back page of a book before deciding whether to invest the time? Ever visit a spoiler site for your favorite TV show for a sneak peek at what’s coming? Ever shake your holiday or birthday presents? Or try to sneak a corner of the tape off and then rewrap it? Yes, brother dear, I am talking to you. Or ransack your mom’s gift closet to see if there’s anything new there? My son did this.

People want to know what to expect. We like to be prepared. In fact, recent research from UC  San Diego suggests that knowing the ending of a book increases our enjoyment.

And we don’t like to be embarrassed.  It is really bad form to embarrass your customers.

Remember this when planning your blogger programs. Building around a big “reveal” is a dicey proposition, and if the reveal might disappoint instead of enchant? Seriously. Go back to the drawing board. Create something that will appeal to your target audience without deception. It may not be as alluring or sexy, but it’s far less likely to backfire. The Sotto Terra backlash was not “bloggers gone wild” by any means. It was people feeling betrayed and deceived. Not a good way to build a relationship.

Lesson Number 3: Disclosure. Do not do programs without disclosing your brand’s participation. EVER! Strictly speaking, I don’t think the Sotto Terra event violates the FTC disclosure guidelines, as full disclosure of the brand’s involvement was provided when the exchange of value (the meal) happened. However, I am not crazy about the ethics here. Bloggers were encouraged to promote an event as a prize, apparently without full information about the sponsor of the event. Could the bloggers have done a little research and learned that the two hosts were ConAgra consultants? Sure. But they shouldn’t have to. That’s your job as the sponsor.

What did you take away from the Sotto Terra story? Please stay away from brand-bashing. I want to focus on what brands, and bloggers, can do better to ensure mutually beneficial outcomes, not on pointing fingers or trashing the participants in this tale.

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