Earlier this summer, the Federal Trade Commission updated their Endorsement Guides FAQ for disclosures in digital advertising. This new document helps provide additional clarity into their 2013 Disclosure Guide, which is a bit ambiguous.
In blogger/influencer brand partnerships, it’s always best to make disclosures clear and conspicuous. If you’re not sure if something is clear and conspicuous, take a step back and look at the content through the eyes of a consumer who doesn’t work in the advertising/marketing industry. Assume this consumer has no idea that bloggers, YouTubers, Instagramers, Viners, etc. get paid by brands to market on their behalf. Is it 100% clear that the content is a partnership with a brand? If not, then you have some editing to do! If it is… good job!
Here are some general guidelines that bloggers/influencers and marketers should follow when working on sponsored content:
1. Make sure to clearly disclose relationships in blog posts.
Again, make sure the disclosure is clear and conspicuous. You can say something like, “This post is sponsored by Brand X,” or “This post is in partnership with Brand X.”
2. Disclose relationships in individual social media posts, too.
Typically, influencers promote brand partnerships on social channels that complement their primary channel (such as their blog or YouTube channel). These complementary social channels include Twitter, Facebook, Instagram, Pinterest, Snapchat, etc. If the brand is mentioned in text (e.g., calling out the brand’s Twitter handle) or image (e.g., the product is visible in the Pinterest image), disclosure needs to be included in that individual piece of social content, too.
Linking to a blog post with disclosure is not sufficient. What if someone never clicks on that link?
3. #sp and #spon are not acceptable disclosures on Twitter, Instagram, Pinterest, Facebook, etc. Use #ad instead.
Many bloggers use #sp and #spon as disclosure. This is a common mistake. The FTC Endorsement Guide cites #spon as insufficient and not clear. A consumer may not realize that #spon or #sp is shorthand for “sponsored.” I see their point here; even I, a marketer, read #sp and think, “Spelling error!” (Elementary school essay flashbacks…)
The easiest solve is to use #ad. It uses the least amount of characters and is undeniably clear. For a softer approach, you can disclose in context such as, “The easiest BBQ brisket, in partnership with @BrandX: [LINK].”
4. Don’t put #ad in the first comment on Instagram.
If multiple people comment, then it will get buried and no one will see it. It needs to be in the description.
5. On YouTube, make sure disclosure is stated verbally both in the video and in the description.
Make sure that the disclosure is featured in the description above the fold, before the “Show More” link. Additionally, disclosure should be stated verbally at the beginning of the video, since YouTube videos are often embedded and a consumer may never see the description. And, as the FTC says, it’s even better to disclose multiple times throughout the video.
6. If you’re working with a blog network, make sure they call out the brand name in the disclosure.
Some blog networks have bloggers disclose with a simple “This post is sponsored by Blog Network X,” without any mention of the brand name. The consumer may think Blog Network X is a neutral third party, so it is not sufficient. The brand name must be mentioned.
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