Bloggers and marketers alike are slowly getting their heads around the new Federal Trade Commission (FTC) guidelines for endorsements and testimonials. It's a simple formula, really:
Endorsement + Compensation = Disclosure Required.
Most bloggers are disclosing the relationship within the post or putting a disclaimer on the post, usually at the bottom. Many have also added editorial/disclosure policies to their blogs, which while not an FTC requirement, is definitely a best practice.
And responsible marketers are doing their part by reminding bloggers who get free product or cash from them to disclose the business relationship if/when they write about the product.
It's all good. Except when it comes to how to disclose on Twitter. That just seems to make everyone's head explode.
The FTC offers the following guidance in a new Q&A about the guidelines:
What about a platform like Twitter? How can I make a disclosure when my message is limited to 140 characters?
The FTC isn’t mandating the specific wording of disclosures. However, the same general principle – that people have the information they need to evaluate sponsored statements – applies across the board, regardless of the advertising medium. A hashtag like "#paid ad" uses only 8 characters. Shorter hashtags -– like "#paid" and "#ad" –- also might be effective.
The general complaint about this solution, which I have heard more than once at conference panels on which I have participated in the past year as a representative of Blog With Integrity, is that the shorter hashtag still takes up valuable characters and interrupts the conversation if it has to be included on every single tweet about the product or service.
Other critics (correctly) bring up the point that #ad or #paid is too broad a brush. It doesn't cover all the potential nuances of a relationship between a marketer and sponsored tweeter. As a result, "tagging" models have been proposed by members of the blogging community and commercial vendors, including a simple system proposed last summer by the folks at ZRecs and a more complex framework proposed by commercial firm CMP.ly. Commercial solution Sponsored Tweets (IZEA) automatically appends a disclosure to tweets.
The danger is that these systems become so complex that you'll need a dictionary to understand them. To get an idea of how absurd this could become, read BlogHer Contributing Editor debontherocks' post Alternative Hashtags for the Discerning Tweeter.
All kidding aside, if you need a lexicon to understand the label, the disclosure probably doesn't meet the FTC's general guidance that disclosure must be clear and conspicuous.
So what's a responsible sponsored tweeter to do? Here are some tips.
The best way to disclose is always in context, whether it's a blog post or a tweet: "Enjoying trip to WDW as guest of Big Swanky Company." "The beach at host hotel Swanky Resort is lovely." "Thrilled to be a guest of Consumer Products Company at their press event."
Hashtags like #sponsored #ad #paid are clear, so go ahead and use them if they work for your tweeting style. Don't use shorthand like #sp, which is NOT clear.
Just using an event hashtag -- even for a fully sponsored invitation-only event -- is probably not sufficient in and of itself, unless you are reasonably assured that everyone reading those tweets understands that it is a sponsored event for all attendees. My advice: Disclose in an initial tweet, so readers have context for your use of the hashtag. For example: "Am v. excited abt being BigCompany's guest at the #BigCoMtg in LA"
If you also are writing a post about the product, event or trip, you can put a short disclosure in the tweet and the longer disclosure in the post. For example, if you were sponsored by Marriott Hotels on a trip to Aruba, your post-trip tweet could be: "Our family trip to Aruba as guest of Marriott (short link)." This also works for product reviews: "My experiences with the Fancy Vacuum Cleaner (short link) #sponsored." Then in the post, you can write a longer disclaimer that explains the business relationship with the marketer.
Twitter disclosure is particularly difficult when an event or trip occurs over a period of days. This was a particularly vexing problem for the bloggers at the Travel Blog Exchange conference last month in New York City. Co-panelist Mary Engle from the FTC offered an important clarification. You only have to disclose when you are tweeting about the company that paid you or gave the free product/service. When you are tweeting about something unrelated to the sponsor, there is no need to disclose.
An example: You are invited by a big consumer products company to a blogger event. They put you up in a nice swanky hotel and pay your expenses. When you tweet about its products, you have to disclose the relationship. If you decide to tweet about how nice the hotel is, you don't, because you don't have a commercial relationship with the hotel.
Of course, if the sponsor is the hotel, you have to do things differently. Here's the specific advice I gave travel bloggers in my post-TBEX conference write-up on how to disclose sponsored trips on Twitter:
- Start your trip with a tweet acknowledging the sponsor (and linking to a post on your blog with more details if you have one)
- Be sure to disclose in some fashion in any tweets endorsing the sponsor: "I love my room at the Aruba Marriott #sponsor" "The beach at host hotel Swanky Resort is pristine."
- If the trip spans multiple days, make sure you have at least one tweet per day that discloses that your trip is sponsored and by whom. The easiest way to do this is to spread out your endorsements of the sponsor
Usual disclaimer: I am not a lawyer and do not play one on the Internet.
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