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Social Media Marketing Disclosure Rules: Five Ways to Steer Clear of Trouble [Slide Show]

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Slide 1 of
121025-1 Intro

When you're driving along a cliff at 100 MPH, it's nice to have guardrails.

As marketers, we're all moving fast. From briefings to conferences to creative reviews and all the rest, we keep a grueling pace. Social media has exacerbated the problem: Now we're expected to launch new programs with breakneck speed and manage consumer engagement with our brands 24/7.

So we're all happy to find ways to work more efficiently, especially if they can help keep us and our brands out of trouble.

Fortunately, the Word of Mouth Marketing Association (WOMMA) recently issued an updated guide to social media disclosure. Read on to learn how the updated guide can help time-starved marketers avoid collisions with the Federal Trade Commission (FTC) and others.

121025-2 Disclosure


The FTC requires (PDF) that social media marketers ensure bloggers or other consumers engaged in marketing programs disclose their connections to brands.

If you plan to promote soap and send 20 bloggers free samples of your product with the expectation they'll write great stuff about it, know that you are on the hook for ensuring these bloggers tell their readers they got the soap for free.

Remember that disclosure isn't up for debate, the FTC requires it.

121025-3 Fair Claims

Fair Claims

The FTC requires that participating consumers accurately describe how products work and that they not overstate the benefits of those products. So if you gave a bunch of bloggers soap, they can't claim that it's made them look 20 years younger or it's made them smarter.

To prevent inaccurate claims, arm your bloggers with the inside story of how your product works, why it's different from competing products, and what the concrete benefits are.

121025-4 Monitoring


You can't "set and forget" your social media programs. The FTC mandates that brands make reasonable efforts to monitor what consumers are saying and get involved when things go wrong.

Ask your bloggers to use specific links so you can track individual posts. Set up systems to filter mentions in social media updates by these bloggers—for example, specific hashtags for tweets.

You will likely need to use a more advanced monitoring system (at the very least Google Alerts) to capture what's being said on various other social media.

121025-5 Social Media Policy

Social Media Policy

The key to ensuring disclosure is providing clear instructions. Write a social media policy and make sure your employees, agencies, and participating advocates read it. The policy should explain what disclosure is and provide examples of acceptable and unacceptable disclosure statements.

WOMMA has also made some suggestions (PDF) about what you should include in your social media policy. (Also see Social Media Marketing: The Full Monty.)

121025-6 Liability


What happens when the FTC guides aren't followed? Remember, it's not just the brand that should care: Liability extends to ad agencies working on the programs, as well as participating brand advocates.

You can steer clear of trouble by making sure your programs stick to the following principles:

  • Transparency
  • Accuracy
  • Honesty
  • Respect

You can find some coverage of FTC investigations into disclosure violations here: and

Slide images doodled by Verónica Maria Jarski.

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Malcolm Faulds is senior vice-president of marketing at BzzAgent, the social marketing arm of dunnhumby.

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  • by Justine Thu Oct 25, 2012 via web

    I like the illustrations, but where's the captions? I can only understand what some of them are trying to convey.

  • by Vahe, MarketingProfs Thu Oct 25, 2012 via web

    Hi, Justine. Look to the right of the images--the right-hand column of the page.

  • by Shyam Ramamurthy Tue Oct 30, 2012 via web

    The reputation of a business can make or break them. As your brand awareness grows, there is more of a chance that your "haters" will share their thoughts about you via social media and other outlets. Although, having contingency plans to combat this is important, having a preventative strategy is more important. Guide your audience with a responsible and honest social media presence via positive and thought provoking content. Curating content from thought leaders in your community to boost your brand awareness will definitely help you not only protect your reputation but also increase your ROI. If you want to know more about how you can become a content curation rock star, download our eBook:

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