Marketing Roadmaps

Blogger relations

Blogger Relations: Where has all the creativity gone?

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There are two principal components of successful outreach strategy. For simplicity’s sake let’s call one Execution and the other Content.

Execution is all the tactical stuff – targeting the appropriate bloggers or reporters, getting the details right — the simple things like name, blog name, email address, following through appropriately, sending review or sample product promptly. Execution is the HOW.

Content. That’s the pitch, the message, the story, the program. Content is the WHY. As in why should I care? Your pitch better answer that simple question straight up, or you will strike out.

Successful outreach programs get both of these elements right. Some recent examples:

No question about it, there are PR and marketing people who really get how to do it right, and are fortunate enough to have clients or bosses who trust them, who let them get it right.

Unfortunately, there aren’t enough of them.

I still see far too many execution errors — the dear blogger, dear xx, sending the same pitch to the same blogger at multiple blogs, forgetting to delete template notes, reforwards of messages without deleting the signature (a recent one had 94 sigs).

Irritating but eventually — hopefully — this will self-correct as tools and training get better and marketers become more sensitive to the potential for stupid, preventable errors. Forming the habit to re-read emails and check attachments before pressing send would be a good start.

The more serious problem is the content.

Agencies are still casting too wide of a net, with too generic a pitch. The lack of creativity is astounding. As is the expectation of what might interest a blogger.

From the inbox:

  • Invitations to promote a contest or support a charity (regardless of whether the blogger has ever expressed any interest in same)
  • The negative competitive pitch. Lead with something negative about the competition and then show how you are so much better. These often are ham-fisted and make the company look like a bully.
  • Requests for the blogger to write about or review a product without an offer to actually send the product. Extra demerits if the blogger asks for product, and the company offers a jpg instead. Or worse, promised product never arrives.
  • My perennial favorite – press releases (especially when they have no cover note)

We also seem far too reliant on BIG programs – trips, free appliances, free consumer electronics. Lately, Twitter seems absolutely cluttered with bloggers announcing yet another giveaway. More More More. Free Free Free.

I’ll leave aside the issues raised by the potential changes to the FTC’s guidelines for commercial endorsements and testimonials.  I think these are manageable, although I do question whether affiliate marketing should be lumped in with commercial endorsements and testimonials. I think not — more next week.

Problems with the BIG blogger relations programs

First and foremost, are they sustainable? One of the phrases that comes to mind is: Begin as you intend to continue. But can they? I think Frigidaire’s current appliance campaign is very clever, but what happens next year?

Another problem is noise. The signal to noise ratio is increasingly out of whack. There are a lot of giveaways and contests announced on Twitter every day, but I’m not sure I could tell you a single brand. It’s becoming a muddle. Full of ethical landmines like companies offering cash to the first 50 reviewers to post about something on iTunes.

Where’s the creativity?

Why aren’t we spending the time to find those commonalities with our customers that create truly memorable campaigns and foster long term relationships. It can be done. We just don’t take the time.

Instead we rely on formulas. For example the tried and true brand ambassador program. There’s NOTHING wrong with a brand ambassador program. Except if the same bloggers get all the invitations to participate, how wide is your message spreading, and what else is it competing with?

Events. Invite x number of bloggers to DisneyWorld or a spa, treat them really well and hope for the best? What are the expectations and are they being met?

And then there’s my favorite – the solution in search of a problem. The latest example is Dunkin’ Donuts’ Dunkin’ Run iPhone app. Sure, it’s cute and clever, but does it solve a real customer problem?

How well do these programs match up to marketing objectives and do they deliver?

The smart folks are measuring. They know when they hit and they know when they miss so they can fix it for next time. In fact, I expect that the good programs I mentioned above  had some form of measurement based on a consumer behavior, not just clip counting or ad equivalency.

This is where we need to place our focus — on developing meaningful relevant campaigns that deliver results.

Relationships are very important, but when you sit down to develop your next program or new business pitch, ask yourself if you are asking the right questions?

Does the program meet the marketing objectives or are you trying to make a favorite tactic fit? Are you going back to the same well, or bloggers,  over and over, because it’s easy, familiar?

This is even more important when outsourcing all or part of a project. You don’t want a cookie cutter program or something developed to meet the goals of another client.

You want a creative program that delivers to YOUR goals.

Do you WANT advertisers to lie to you?

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Today, an AP story about the FTC’s review of the guidelines for testimonials and endorsements and a John Dvorak PC Mag column about same stirred up the blogosphere a wee bit, although the scintillating *yawn* news of Jon & Kate plus 8 minus 1 seemed a potent distraction.

While the spate of coverage leads me to wonder if the FTC is getting closer to announcing the new guidelines — the AP prefers to lead, not lag, the news — nothing was announced today. Apart from the fact that it is officially summer, nothing has changed since the last round of posts and articles on the topic one month ago.

The FTC is reviewing its guidelines on endorsements and testimonials and expects to issue new ones this summer. These guidelines will affect social media and viral marketing. They may also impact affiliate marketing, such as Amazon.

If you are upset about this,  I have some questions for you.

  • Do you want advertisers to lie to you?
  • Do you want to wonder whether a commercial endorsement is honestly from the heart of the writer, or from the keys of a copywriter?

Right. I didn’t think so.

The enforcement guidelines on endorsements and testimonials  exist to make sure that consumers have the information they  need to judge a commercial endorsement. That is the FTC‘s job, to protect consumers .

The Federal Trade Commission is the nation’s consumer protection agency. The FTC’s Bureau of Consumer Protection works For The Consumer to prevent fraud, deception, and unfair business practices in the marketplace. The Bureau:

  • Enhances consumer confidence by enforcing federal laws that protect consumers
  • Empowers consumers with free information to help them exercise their rights and spot and avoid fraud and deception
  • Wants to hear from consumers who want to get information or file a complaint about fraud or identity theft

Consumers.

That’s us.

It’s NOT about the blogger, or your credibility. It’s about whether the reader — the consumer – would have a different impression of your opinion if it were compensated versus unsolicited. Your ethics could be impeccable, your opinion unchanged by the commercial transaction of free product or paid post. It doesn’t matter.

It’s not about you.

It’s all about whether the reader would have a different understanding, and you can’t decide that.

Hence the guidelines, so we can understand our responsibilities under the law, and the need for disclosure.

This doesn’t mean bloggers shouldn’t accept review product or free trips or whatever else companies might be offering for consideration. If you’ve got a property that companies consider valuable, why not profit from it. You just need to understand that under the FTC rules, if you are compensated, either directly or in product, the FTC guidelines for commercial endorsements may apply to you.

I recommend that bloggers publish their review and disclosure policy on their blogs, and if active on social networks like Facebook, Twitter and LinkedIn, a policy that covers your potential activities in these networks. I had updated my blog statements a month ago, but today I added links on Facebook and Twitter to clarify how I might mention products on these status-oriented sites.

Your readers decide if you are credible.

The FTC is just asking that you provide them with all the information they need to make that assessment. That’s everything from what and how you say it, to whether you may have been influenced by others.

You want that from the sites and blogs you visit.

Don’t begrudge it to your audience.

Marketing Roadmaps (and me) around the blogosphere

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I’m testing Social RSS on my Facebook Profile, and need a new post quickly to make sure it posts a new entry to the Wall, so you lucky readers are being treated to a list of places around the blogosphere where I have appeared or contributed in the past couple months. Enjoy!

Diva Talks! Blog Talk Radio podcast. Toby Bloomberg invited Liz Gumbinner (Mom 101, Cool Mom Picks) and me to talk about the best ways to reach out to bloggers. Especially parent bloggers.

Open the Dialogue, MWW Group’s social media blog – Guest post on the differences between bloggers and journalists (May 28) and Interview (June 15th). All about blogger relations, baby.

While you’re over at Open the Dialogue, check out m.insight, MWW’s new mobile app for downloading marketing & pr news feeds right to your phone.

Radical Parenting – Interview.

communicationcontrolling.de – I wrote an article about April’s New Comm Forum for this German online publication.

Impact of potential new FTC endorsement guidelines on companies

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Yesterday, I gave you my take on how the potential new FTC guidelines for endorsements and testimonials might impact bloggers. Today we are going to look at the potential impact on companies.

A couple of things to keep in mind:

  • The guidelines outline how the FTC intends to enforce the laws governing endorsements and testimonials in commercial speech. They are meant to be used as an aid to compliance. The new bit is that they are clearly extending the definition of commercial speech into certain social media activities.
  • The FTC is still working on these new guidelines, but has said they’ll be out this summer. The new guidelines  could change a little or a lot from what it outlined in the call for comments I reviewed, based on the comments received, lobbying and so on. I’m betting a little, but I could be wrong. Been known to happen.

How might companies change/have to change their blogger relations programs and practices to comply with the guidelines?

First, let’s review the three examples related to blogs. The citations are the direct quotes from the document; headlines and emphasis mine. Please note,  I’ve changed the emphasis from yesterday’s post. It now reflects the impact on the company. Also, be aware that there is a fourth example specifically related to in-person word-of-mouth marketing, “street teams,” such as the work done by firms like BzzAgent. That’s not my area of expertise, so I’ll leave that one to WOMMA.

Number one: Liability for false statements in a sponsored post.

“Example 5: A skin care products advertiser participates in a blog advertising service. The service matches up advertisers with bloggers who will promote the advertiser’s products on their personal blogs. The advertiser requests that a blogger try a new body lotion and write a review of the product on her blog. Although the advertiser does not make any specific claims about the lotion’s ability to cure skin conditions and the blogger does not ask the advertiser whether there is substantiation for the claim, in her review the blogger writes that the lotion cures eczema and recommends the product to her blog readers who suffer from this condition. The advertiser is subject to liability for false or unsubstantiated statements made through the blogger’s endorsement. The blogger also is subject to liability for representations made in the course of her endorsement. The blogger is also liable if she fails to disclose clearly and conspicuously that she is being paid for her services. [See § 255.5.]

In order to limit its potential liability, the advertiser should ensure that the advertising service provides guidance and training to its bloggers concerning the need to ensure that statements they make are truthful and substantiated. The advertiser should also monitor bloggers who are being paid to promote its products and take steps necessary to halt the continued publication of deceptive representations when they are discovered.”

Number two: Disclosure of receipt of free product

“Example 7: A college student who has earned a reputation as a video game expert maintains a personal weblog or “blog” where he posts entries about his gaming experiences. Readers of his blog frequently seek his opinions about video game hardware and software. As it has done in the past, the manufacturer of a newly released video game system sends the student a free copy of the system and asks him to write about it on his blog. He tests the new gaming system and writes a favorable review. The readers of his blog are unlikely to expect that he has received the video game system free of charge in exchange for his review of the product, and given the value of the video game system, this fact would likely materially affect the credibility they attach to his endorsement. Accordingly, the blogger should clearly and  conspicuously disclose that he received the gaming system free of charge.”

Number three: Anti-astroturfing. Requires disclosure of material interest when making an endorsement.

“Example 8: An online message board designated for discussions of new music download technology is frequented by MP3 player enthusiasts. They exchange information about new products, utilities, and the functionality of numerous playback devices. Unbeknownst to the message board community, an employee of a leading playback device manufacturer has been posting messages on the discussion board promoting the manufacturer’s product. Knowledge of this poster’s employment likely would affect the weight or credibility of her endorsement. Therefore, the poster should clearly and conspicuously disclose her relationship to the manufacturer to  members and readers of the message board.”

Sponsored Posts/Blogs

There are a few flavors of sponsorship. The company might pay the the blogger directly for a post or as an advertising sponsor of the blog, it might pay a blog network like BlogHer for access to its members or it might work with a sponsored post company like Izea.

In the first case, when the company works directly with a blogger, for example by sponsoring a specific post or even the blog as an advertising sponsor, the relationship should be governed by an advertising contract that outlines the responsibilities of the parties, and the nature of the relationship clearly disclosed on the blog. This is just smart business for both sides.

If, however, the company is not working directly with the blogger and instead is working through an intermediary, described in the FTC doc as a blog advertising service, the company needs to perform an additional level of due diligence. It needs to be sure that the advertising service is providing guidance and training to its bloggers, and if free product or services are provided, requiring disclosure of the commercial relationship.

Note that there is no requirement that the blogger be receiving a payment. Or even free product. If a company uses a blog network to reach out, is paying the blog network for the access to its members, that seems to be sufficient for liability for false statements.

What kind of policy should you look for in a blog advertising network or sponsored post firm? A good example is BlogHer. It  has done a nice job navigating this minefield. The blog network you use may not have exactly the same policies, which is fine, but you want it to have at least paid as much attention to its own policy. To understand and be sensitive to the impact on both the blogging community and the advertiser.

Is there an issue if you are working with a consultant or agency to reach out to bloggers on your behalf, but who has not promoted a blog network as a product? In this case, the vendor would be building an outreach list based on your criteria and probably its relationships, but it isn’t advertising a blog network service.  I do not think the same liability exists, but usual disclaimer. Not a lawyer, don’t play one on the WWW.

{added 5/21 7:50 am}

After sleeping on it, I realized the above paragraph wasn’t clear. I don’t want to read too much into the examples, so be aware that this next thought is my interpretation, not a direct example from the FTC document.

It is the payment to the blog network combined with the explicit agreement that the bloggers will write that creates commercial speech, ie advertising. When blogger outreach is handled more like public relations, as it would be by a PR agency or an independent consultant like me, there is no agreement that the bloggers will write. Our job is to present a relevant story to a group of bloggers that we expect will be interested. If they write, it is editorial.

If free product is provided to them, the same disclosure provisions would apply. In both cases, whether there is agreement to write or not, best practice is to provide as much information as the blogger needs/requests, but no direction as to post tone, content or timing.

{end insertion}

Free product considerations

Many blogger relations programs include something for free. A product. A trip. Products to giveaway on the blog. While the FTC example doesn’t require you, the company, to do anything, I recommend that you act as though it does, and advise bloggers of the need to disclose.

Should you stop offering review product or developing blogger events? Absolutely not. Even with these new guidelines, honest customer experiences of your products and services are a great way to reach other customers. We all just need to understand that it is a new form of advertising and act accordingly.

A word about contracts. The temptation will be strong, particularly in your legal department, to pass as much liability onto the blogger as you can. My advice is to be reasonable. If the value of the goods received, either for loan or free, is high, you probably need a contract that spells out the responsibilities of the parties. But, if you try to pass on all the responsibility to the bloggers, be prepared for them to walk away. And if you’re just sending the blogger a few DVDs or product samples to try and perhaps give away on her blog, be realistic. A contract?

A form of astroturfing specifically prohibited

The astroturfing example warmed  my cold cynical heart. Far too many companies and agencies have engaged in the  practice of leaving positive comments on blog posts and forums without disclosing their interest in the product or service being discussed. This is an abhorrent, unethical practice. If the example above makes it into the final guidelines, this will be considered deceptive advertising subject to FTC enforcement. AMEN.

Better practice by far is to participate but disclose your interest. In most cases, you’ll be better off communicating with the site or forum owner first, privately, before jumping into a forum, community or ongoing blog discussion, but some will already have threads for vendor discussion. Once you’ve established a relationship with the community, you may even become a resource for it. Isn’t that what we really want? Robust relationships with our customers and influencers.

What’s the bottom line?

The potential new FTC guidelines change the playing field for social media outreach, but only slightly, and really, well within what we should be doing as  ethical practice anyway.

The FTC’s job is to protect consumers from deceptive advertising. One of the ways it does this is to make sure that commercial speech — paid advertising in all its forms — is clearly marked as such. While it may make our jobs as marketers and bloggers a bit more complex, as consumers, we should be glad that we have this watchdog on our side.

The FTC is NOT gunning for mom bloggers

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Articles in the mainstream press, like this one today in BusinessWeek, give the impression that somehow the Federal Trade Commission is targeting mom bloggers for “enforcement.” Poppycock.

The FTC is doing a review of its guidelines on endorsements and testimonials. That’s part of its job — to protect the consumer from deceptive advertising practices. In 2007, it published notice of its intent to review these guidelines and solicited comments. Last year, it published this document, soliciting additional comments, which were accepted until earlier this year.

In the process, new media got added to the mix because word of mouth marketing, whether done by guerrilla marketing agencies or bloggers, is a new form of endorsement.

The question then becomes is it a commercial endorsement or not. If commercial — if it qualifies as advertising — then the guidelines may apply.

Why is this an issue for mom bloggers?

Not because the FTC is targeting them. It is not. However, consumer products companies are, big time. Bloggers are being asked to endorse products in a variety of ways, from sponsored posts to free product to big events and trips. So, what is the real impact of the possible changes to the guidelines?

A long time ago, when I wasn’t much older than my son is now, I thought I wanted to be a lawyer. Which may explain why I still get off on reading 86 page policy documents from the FTC. The good news is, I do, so you don’t have to. Today, I reviewed the FTC call for comments on the guidelines, the most recent public document we have.  Here’s the scoop.

The bulk of the 86 page document focuses on deceptive use of testimonials in advertising, largely for weight loss, baldness and other pharmaceutical (and quasi pharmaceutical) products.  Disclosure of the relationship among the parties and substantiation of claims are the main themes.

There are only three examples related to blogs. The citations are the direct quotes from the document; headlines and emphasis mine.

Number one: Liability for false statements in a sponsored post.

“Example 5: A skin care products advertiser participates in a blog advertising service. The service matches up advertisers with bloggers who will promote the advertiser’s products on their personal blogs. The advertiser requests that a blogger try a new body lotion and write a review of the product on her blog. Although the advertiser does not make any specific claims about the lotion’s ability to cure skin conditions and the blogger does not ask the advertiser whether there is substantiation for the claim, in her review the blogger writes that the lotion cures eczema and recommends the product to her blog readers who suffer from this condition. The advertiser is subject to liability for false or unsubstantiated statements made through the blogger’s endorsement. The blogger also is subject to liability for representations made in the course of her endorsement. The blogger is also liable if she fails to disclose clearly and conspicuously that she is being paid for her services. [See § 255.5.]

In order to limit its potential liability, the advertiser should ensure that the advertising service provides guidance and training to its bloggers concerning the need to ensure that statements they make are truthful and substantiated. The advertiser should also monitor bloggers who are being paid to promote its products and take steps necessary to halt the continued publication of deceptive representations when they are discovered.”

Number two: Disclosure of receipt of free product

“Example 7: A college student who has earned a reputation as a video game expert maintains a personal weblog or “blog” where he posts entries about his gaming experiences. Readers of his blog frequently seek his opinions about video game hardware and software. As it has done in the past, the manufacturer of a newly released video game system sends the student a free copy of the system and asks him to write about it on his blog. He tests the new gaming system and writes a favorable review. The readers of his blog are unlikely to expect that he has received the video game system free of charge in exchange for his review of the product, and given the value of the video game system, this fact would likely materially affect the credibility they attach to his endorsement. Accordingly, the blogger should clearly and  conspicuously disclose that he received the gaming system free of charge.”

Number three: Anti-astroturfing. Requires disclosure of material interest when making an endorsement.

“Example 8: An online message board designated for discussions of new music download technology is frequented by MP3 player enthusiasts. They exchange information about new products, utilities, and the functionality of numerous playback devices. Unbeknownst to the message board community, an employee of a leading playback device manufacturer has been posting messages on the discussion board promoting the manufacturer’s product. Knowledge of this poster’s employment likely would affect the weight or credibility of her endorsement. Therefore, the poster should clearly and conspicuously disclose her relationship to the manufacturer to  members and readers of the message board.”

So what’s the big deal? Doesn’t this all make sense?

It will come as no surprise to readers of this blog, but apparently to some: businesses do not always act in the best interests of consumers. Sometimes they even lie. That’s why we’re in a recession.

The FTC protects us from deceptive practices in advertising, and extending the policies to social media that qualifies as commercial speech makes sense. If you are a blogger, that may include some of your writing. But please don’t over-react. The FTC is not interested in honest reviews of products by bloggers.

It is interested in protecting the consumer. Us.

What should bloggers do?

Well the document I read today merely outlines the direction the FTC was taking. The final guidelines could be slightly or even very different. Nevertheless, I’ll stand by my original post on this topic (Bloggers liable for statements about products? Maybe says FTC ) and say that the key issues will be compensation and disclosure. To what extent is the blogger a proxy for the advertiser?

In that context, here’s my advice. Keep in mind:  I am not a lawyer and I do not play one on the Internet.

1. Whether you write paid posts, go on paid trips or take free products for review, or not, review your blog disclosure policies. Are you clear about your interests and affiliations?

I have three blogs, and each has a slightly different policy. Marketing Roadmaps accepts no advertising whatsoever. Snapshot Chronicles, my personal blog, runs BlogHer ads and is an Amazon affiliate. Snapshot Chronicles Roadtrip, my new family travel blog, accepts review product and advertising with the policies clearly spelled out.

For reference, here’s the general policy for the Snapshot Chronicles.com domain and for the Getgood.com domain that hosts the Marketing Roadmaps blog. Every blog I build for a client has a similar policy. Every one.

If you feel better having a lawyer review your policy, go for it. Especially if you are making money from your blogging or you are in partnership with other bloggers. It’s your business. Protect it.

2. If you accept compensation for a blog post, disclose the payment. If the post was written as part of a blog network, even if you are not compensated directly but the network is, disclose. When in doubt, disclose.

3. If you accept free product, whether or not there is an explicit agreement for a review, if you do the review, disclose. Also, as Erin Queen of Spain pointed out on Twitter today, don’t forget your tax liability for free products. Personally I think it far more likely that the IRS will come knocking than the FTC. Cover yourself.

4. Be careful about claims you make about the products. In the skincare lotion example, there’s a big difference between saying “This cream cures eczema” (Wrong) and “This cream really helped my eczema.” (Specific, probably acceptable). In advertising, commercial speech, general claims must be substantiated.

5. It would be nice, wouldn’t it, if the FTC would say something like free product over $x dollars is subject to the guidelines, but under, it is not. Abandon that hope. It won’t happen. Absolute numbers are a policy mistake, and one that I do not see the FTC making in this case.

Use your common sense. If you take a book or DVD or baby sling to review, something you might purchase anyway, the FTC probably isn’t going to spend any time worrying about deception in your review. Sorry.

A new car? A free trip? A suite of brand-new appliances? Uh. Yes. These are levels of compensation that may get some scrutiny. Should that prevent you from participating in a blogger program? Absolutely not. Assuming everything about the program is kosher, that would be stupid. The FTC is focused on deceptive practices, not honest reviews.

Stay on the side of the angels. You’ll be fine.

This post has focused on the blogger side of the blogger relations equation. In the next few days, I’ll share some thoughts on how the proposed changes might impact what companies and agencies do.