Marketing Roadmaps has been pretty serious of late, and likely will be so again as I continue to dig into topics related to the FTC endorsement guidelines. But today, my friends, I received an email pitch I just have to share with you.
Here’s the pitch:
And here’s the accompanying picture:
I guess someone thinks I’ve got a set….
Today the FTC published the final guidelines for endorsements and testimonials. Nothing terribly surprising, although I was pleased to see some additions to the examples about blogging and word of mouth marketing that made things much clearer. [Full text of the changes to the guidelines (pdf) as submitted to the Federal Register.]
More from me on this later this week. We’ll also be updating and repeating the Blog with Integrity webinar on disclosure to reflect the final approved guidelines. Follow @BlogIntegrity on Twitter, fan on Facebook or subscribe to the email list for updates.
In the interest of full disclosure, I will be tweeting live from the Ad Club of Boston’s Hatch Awards tomorrow, courtesy of an invite from the folks at 360 Public Relations. Hashtag #AdClub.
This is the last of the re-runs. I’m due back in the US tomorrow and will do my best to have a new post up by the weekend.
Just a few of my favorite posts.
The Four Ps of Social Media Engagement (12/12/07)
The secret sauce for the perfect pitch (8/13/08)
New Comm Forum: the 5Cs of Viral Marketing (3/11/07)
Personal Brand? (3/31/09)
The FTC is NOT gunning for mom bloggers (5/19/09)
Should public relations firms have Facebook Fan Pages? What’s the point really? Do PR firms really have fans, and if they do, should they? Isn’t PR about promoting the client’s interests?
That’s the gist of a conversation thread on Twitter over the past few days. Good friend Geoff Livingston (@GeoffLiving) thinks it is silly for PR firms to have Facebook Fan Pages, in part I imagine (and I don’t want to put words in his mouth, this is my impression of his comments) because it smacks too much of “personal branding,” a concept we both loathe.
I agree, and yet I don’t. Or more accurately, I don’t mind that PR firms are setting up Facebook Fan Pages, as long as they don’t go overboard and start spamming my Facebook Wall with self-serving promotional bullshit.
Facebook Fan Pages are becoming a useful element for a company’s marketing plan, and agencies/consultants need to gain experience with the form. Even if they have clients with Pages, they still need a place to experiment. Client sites are generally not good places for messing around with beta stuff.
So, I’m okay with PR agency fan pages. Happy to “fan” you if asked. As long as you don’t take yourself too seriously and think I want your autograph or something. Because, seriously, I don’t even ask real famous people for autographs.
Fame. Fans. One more brief point about the term fan before I move on to the ridiculous idea of mom blogs “boycotting PR.”
I like the term Fan Page. Not simply because the number of fans shows how popular a brand or company is. I like it because it highlights how the brand should be thinking of its customers. Not simply as consumers. Fans are engaged consumers. They don’t just buy a product, they love the product.
And the brand should love them back. Not take them for granted. Add value beyond the simple transaction. That’s what a Fan Page should be about.
Most are not, or at least I hope, not yet.
Facebook has more than 200 million users.
The brands that get it? That understand that the Fan Page isn’t just a billboard for product announcements? That truly make the effort to engage with the customers?
They are going to have lots and lots of fans.
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“But he hasn’t got anything on,” a little child said.
– Hans Christian Andersen, The Emperor’s New Clothes
Today, mom blog site Mom Dot proposed that mom blogs should boycott PR and marketing offers for a week in August. The rationale has something to do with marketing firms taking advantage of mom bloggers by sending them free products. I think. Or maybe it was that mom bloggers are burnt out from the burden of doing product reviews. Something like that. I think.
Seriously, I am not trying to be mean. I really cannot figure out the reason for the boycott. If product reviews are too much work, don’t do them. Or do fewer. If you aren’t getting joy from something, stop. If the value isn’t there, don’t do it.
But a PR boycott? As CNET pointed out, this misses the point by more than a country mile.
The FTC is reviewing its guidelines on endorsements and testimonials. Without a doubt, blogs (and other new media) will be included.
This has caused a great deal of buzz around the issue of free products and other blogger compensation, particularly in the parent blogosphere. Latest media outlets, and by no means the last, to cover the story: ABC and the New York Times.
The issue isn’t the reviews. Or the free products. The issue is disclosure.
It’s about ethics. And integrity.
If you are a blogger, it’s about disclosing your relationships with companies that have provided you with free products or compensation so your readers can properly evaluate your recommendations.
If you are a company representative, it’s about reaching out to bloggers with respect. If you are hiring someone to write a document for you, you can read it before publication. Sending a product for review? Absolutely not. Don’t even ask. If you do, you are either scum or a nØØb.
So, I have another suggestion. Instead of polarizing boycotts, teeth gnashing and wailing, let’s all pledge to Blog with Integrity.
All this really requires is that you publish a clear review and ethics policy on your blog. It doesn’t matter what the policy is — your readers will decide that issue. What matters is that you clearly disclose.
This will help you, marketers who want to reach out appropriately and your readers. And, I’m guessing, the FTC will like it too.
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In other news, Michael Jackson is still dead.
Recently Word of Mouth on NH public radio interviewed Rich Cleland, Assistant Director of the FTC’s Advertising Practices bureau about the revised guidelines on endorsements and testimonials that are expected to be approved this summer. Liz Gumbinner from Cool Mom Picks and Mom-101 provided the blogger’s perspective.
There really wasn’t anything new or unexpected. I’ve written about this topic as has Liz. What was nice was to actually hear it directly from the FTC rather than filtered through another source like AP or BusinessWeek.
Here’s my takeway from the interview:
What they did NOT discuss on Word of Mouth was affiliate marketing, which the AP story said would be included:
“… the guidelines also would cover the broader and common practice of affiliate marketing, in which bloggers and other sites get a commission when someone clicks on a link that leads to a purchase at a retailer. In such cases, merchants also would be responsible for actions by their sales agents – including a network of bloggers.”
I’ve read the initial draft of the changes to the guidelines, and it does not include an example specific to online affiliate marketing such as Amazon. While I expect changes to draft in the final guidelines, I never made the connection between endorsements & testimonials, and affiliate ads like Amazon. Blog networks that offer free products or compensation to bloggers, absolutely. Campaigns that offer compensation to users for reviews on Amazon or iTunes. Again, clearly subject to the guidelines.
But simple affiliate marketing programs?
After much thought and conversation, I don’t think affiliate marketing should be lumped together with the guidelines on endorsements and testimonials. If the FTC wants to review online affiliate marketing practice, it should do so in a separate effort and allow sufficient time for public comment.
Affiliate marketing is a different type of advertising
A review of a product that is compensated in advance by either cash or free product should be considered a form of advertising. The FTC guidelines should apply.
The affiliate marketing relationship is different.
The blogger reviews or mentions a product on her blog and provides a link to a store that carries the item. For example, Amazon. It’s a referral. The blogger is only compensated if the buyer purchases the product from that link.
The explicit endorsement is of the product, although no one would deny that there is also an implicit endorsement of the store, especially if the blog also shows a search widget for the store in its sidebar.
However, once the buyer is at the store, the influence of the initial mention or review is diluted — by the advertising material on the store, by reviews from other consumers, by alternate product suggestions from the store. The blogger’s original opinion becomes one of many sources of information. If the buyer goes ahead and purchases something from the visit created by the affiliate link, the compensation is really nothing more than a “thank you for telling your friends about us.”
Now, if the blogger received the product for free, it should be disclosed under the guidelines. But it should be the free product that trips the endorsement guidelines, not the affiliate referral.
Affiliate marketing is understood by Internet users
Whether you see an ad like this:
or embedded links within a post like these Sleep Is for the Weak
In the very long FTC guidelines document, a key condition of the additional disclosure requirement is if the consumer would not otherwise understand that an endorsement was compensated or that the speaker had a material interest. If the consumer would understand that the speech or action was compensated, the public interest does not require additional disclosure.
Examples — An athlete wearing name brand sports apparel is assumed to have a contract with the manufacturer. A celebrity on the red carpet is assumed to have borrowed her gown from a designer. A public figure endorsing a product in a TV commercial didn’t do it for free.
Affiliate advertising on blogs is similar. We don’t need additional information to know there’s compensation. It looks far too much like straightforward online advertising for there to be any real confusion.
What should bloggers do if they have affiliate marketing relationships?
The new FTC guidelines are due later this summer. We’ll see then how affiliate marketing is covered (or not) in the document. It wasn’t in the initial draft, so we don’t have an example yet.
In the meantime, if you have affiliate marketing relationships, I suggest disclosing them clearly in your blog policy.
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The Amazon affiliate links used above for illustrative purposes are for books written by friends and use the Amazon affiliate account from my personal blog Snapshot Chronicles. So yes, if you buy a book, a friend gets a sale and I get a teeny weeny commission.
