By Jan Carroza
The FTC updated its guidelines for advertisers last year with regard to testimonials and endorsements to incorporate the impact of the new emerging technologies. Of key concern was the trend by bloggers to promote items without acknowledging payment, product or other compensation.
Why is this important?
“…both advertisers and endorsers may be liable for false or unsubstantiated claims made in an endorsement – or for failure to disclose material connections between the advertiser and endorsers. The revised Guides also make it clear that celebrities have a duty to disclose their relationships with advertisers when making endorsements outside the context of traditional ads, such as on talk shows or in social media,” according to the FTC’s release.
Each blogger, personality and affiliate needs to make these disclosures, remembering that by doing so they can show due diligence and demonstration their credibility to build and retain their reputation. Advertisers must monitor communications about their brand to make sure their employees, agents, contractors and talent all comply. For advertisers, it’s not only about reputation, but the costs in time and litigation to defend false claims.
So it’s only appropriate that Cmp.ly, aptly named for advertisers, bloggers, affiliates and celebrities who want to be compliant with these guidelines, should provide a service to note in documents, sites and social media the relationship between the author or celebrity and advertisers.
It’s a simple system and reminds me of the Creative Commons system which offers a variety of copyright options. The author can choose a disclosure and generate the appropriate badge to use on websites. From Diggcomm’s release:
Cmp.ly provides six standard disclosures that are intended to cover all material connection disclosures. Each disclosure is identified using a number as follows:
CMP.ly/0 – No connection, unpaid, my own opinions
CMP.ly/1 – Based upon a review copy
CMP.ly/2 – Given a sample by vendor/agency/brand
CMP.ly/3 – Paid post – cash payment or other compensation
CMP.ly/4 – Employee/shareholder/business relationship
CMP.ly/5 – Custom Disclosure
For ad agencies with multiple accounts, there is a complete set of tools to create disclosure policies and “badges” for each campaign. Bloggers and affiliates must review and accept the advertiser policies prior to joining the program. Advertisers and agencies can then monitor an audit trail of activities.
An affiliate, for instance, running ads with landing pages, blogs, and sites to promote products for a share of the sale will want to use the following badge:
For the occasion of this blog post where no monetary or other consideration has been paid, I would use the following badge:
Whether advertisers, bloggers, and affiliates choose Cmp.ly or any other method of sharing their disclosures, these need to be made in a public way to protect the reputations of all concerned. Bloggers want to keep their audience, advertisers want to keep consumers and stay out of litigation, and affiliates want to keep the money rolling in. While it’s one more step in the creative process, it’s a valuable one.
So go forth and disclose. Herewith, is ours:
Disclosure Text : I have not received any compensation for writing this content and I have no material connection to the brands, topics and/or products that are mentioned herein.