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  • Kristen Zufan
    03.13.2013

    FTC Compliance in Social Media: Do’s, Don’ts and Tips for Marketers

    As marketers, we’re tasked with staying current on the ever-evolving social tools/apps/platform enhancements that relate to our industry. Let’s face it—it’s a lot to keep up with! So, if you’re still determining whether to incorporate Vine into an engagement plan or didn’t watch last week’s Facebook press conference in real time, I get that. However, all marketers do need to have a firm grasp on FTC’s Guides Concerning the Use of Endorsements and Testimonials in Advertising. If you work with an influencer or brand advocate program—and there’s a good chance you do—this is especially important to get smart about.

    At ComBlu, we help major brands identify, recruit, activate, and engage advocates and influencers—and sometimes the engagement part involves providing a product or service for participants to review. This is where FTC compliance comes in. As of December 2009, when the FTC revised its regulations about endorsements and testimonials in advertising, bloggers (and Twitter and Facebook users) are required to disclose when they have a “material connection” to a brand. In layman’s terms: if a blogger receives cash, products, or services, they must make it clear to their readers.

    There’s a fair amount of misinformation on the topic, which may make compliance seem confusing. But after working with hundreds of bloggers across several advocate and influencer programs, I promise that it doesn’t need to be. In fact, I’ve narrowed down my advice on the subject to just five do’s and don’ts.

    1) Do familiarize yourself with WOMMA’s Social Media Marketing Disclosure Guide. The Word of Mouth Marketing Association is the authority on ethical word of mouth marketing. So it’s no surprise that they’re a great starting point when it comes to understanding the ins, outs, and expectations of disclosure. Their Guide is a “living” document, it’s easy-to-understand, and it’s legit. In fact, the FTC themselves often reference the WOMMA Code.

     

    2) Don’t make it difficult for bloggers to comply. If you want to ensure that bloggers consistently follow disclosure guidelines, make it simple. At ComBlu, we offer bloggers several tools. We provide a variety of disclosure language so they can select one that best fits the voice and tone of their blog. For platforms like Twitter where space is at a premium, we create a branded bit.ly that directs readers to a landing page with full disclosure info. And we also provide program badges to include with each blog post. Here is a sample badge from one our programs:

    12VDM2347-Final

    3) Do provide training. Bloggers who have previously worked with brands are often already familiar with FTC disclosure. But that doesn’t mean everyone in a new program really understands how to be FTC compliant. Even experienced bloggers may not fully recognize their responsibilities. So educate bloggers at the start of every program. Emphasize the importance of compliance, review the brand’s expectations, give examples, and (gently) explain the consequences for repeatedly failing to comply. Ideally, training should be conducted in person or via a webinar so there’s an opportunity for Q&A. If that’s not an option, consider a welcome kit or “compliance checklist.”

    4) Don’t forget to monitor activity. You’ve provided the necessary tools and training. So, you’re done now, right? Sorry to say, but the answer is a resounding no! Since you’re working with people—not an infomercial rotisserie—you cannot “set it and forget it.” Marketers are responsible for monitoring their campaigns and making reasonable efforts to outreach to participants whose blogs/tweets/Facebook posts don’t comply. This may seem overwhelming, but since you’re already tracking posts for measurement purposes and to identify potential problems (you are doing that, aren’t you?), be sure to build in a process to check for compliance at the same time. This brings me to my final tip.

     

    5) Do put processes in place. Establish procedures for checking for compliance, recording activity, and communicating with noncompliant participants before your program or campaign kicks off. This includes creating an activity log and drafting communications to bloggers.

    Have additional do’s, don’ts, or tips to add to the list? If so, please share!

    March 15 edit: The FTC just released “Dot Com Disclosures.” This is the most significant update since 2009. Major takeaway is that disclosure must be clear—not cryptic—regardless of the platform. Rule of thumb: Does Grandma understand it? You can read the entire, example-filled guide here


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  • Kristen Zufan
    12.06.2012

    Brand Advocacy Marketing: Inquiring Minds Want to Know

    Marketers are getting smarter when it comes to brand advocates. They realize that advocates can be a powerful word-of-mouth and amplification channel. They understand that advocates need to be engaged in meaningful ways to have the most impact. And they (hopefully) recognize that just because a person “likes” a brand’s Facebook Page, they won’t necessarily go so far as to defend the brand.

    The increased understanding and adoption of advocacy marketing can be attributed to both experience as well as the plethora of case studies and research that exist. Many of the studies, such as Deloitte’s “A New Breed of Advocates” or eMarketer’s “Brand Advocates: Scaling Social Media Word-of-Mouth” focus on advocates’ characteristics and behaviors. This information is important to understand basic things like how much more likely an advocate is to recommend or what motivates them. But at WOMMA and ComBlu, we were left with a lot of unanswered questions.

    So, What Don’t We Know?

    What’s missing is a comprehensive study from marketers’ perspective. A study that doesn’t simply ask whether marketers will allocate more or less budget in the coming year, but examines specific approaches and strategies. Are brands incentivizing advocates? Is it with intrinsic or extrinsic rewards? What methods or tools do brands use to identify their advocates? Do their advocates participate in a formal onboarding process?

    In other words, there’s a void in research that looks beyond who are brand advocates and what they do. We want to know how marketers engage advocates, segment them by behaviors and motivations, leverage them as an asset, and measure their ROI. A “state of brand advocates” study, per se. Inquiring minds want to know!

    This is Where You Come In!

    To address this, we’ve teamed up with WOMMA and developed the 2013 WOMMA/ComBlu Brand Advocates survey. The questions aim to uncover insights into the way brands work with and benefit from their advocates. It takes 10 minutes to complete.

    We’d love for you to participate in the survey. If you do, we’ll be happy to send an advance copy of the results. We look forward to analyzing the research and sharing our findings!

  • Jennifer Voisard
    07.31.2012

    Part 2: Engaging Brand Advocates

    In my last post, we talked about the fact that advocacy marketing was hot and trending again. We covered the nature of brand advocates, their personas, the business value they deliver and their influence. Today, we will expand on this topic and focus on how best to engage with advocates in a meaningful way.

    Incenting advocate participation

    Identifying brand advocates is a bit less complex these days. With all of the social platforms and tools, brands do not need to go further than their own backyards to find a pool of hand raisers. We can quickly monitor the nature of participation on our owned social assets to determine advocate type, brand affinity, purchase behavior, experience/expertise and influence.

    The tricky part is that advocates are not created equal and they choose to participate in different ways. That is why a multi-faceted engagement strategy is important. Not everyone will blog or create stories—in fact, only a very small percentage behave that way. Some will spend an exorbitant amount of time lending their support and helping others in forums. Some folks simply comment or rate content, while others may be willing to share and amplify your message.

    Understanding their behavior is the key to sustained engagement, because true advocates are not paid. You need to provide an experience that offers the types of rewards that will intrinsically motivate them to participate—and most importantly, to recommend and defend you. You can fulfill on their basic needs by:

    · Providing exclusive access to products, news and other branded content they can’t get anywhere else

    · Listening, soliciting and using (when possible) their input on your products and services, as well as the program itself

    · Showcasing individual contributions (we call this microfame)

    · Allowing them to demonstrate their knowledge and expertise

    · Providing a place for them to connect with each other

    · Thanking them for all they do

    Create your space

    Look to your business requirements and make sure you have the appropriate platforms or tools. You will need some type of a centralized place to engage with them.

    A component of the experience needs to be private, outside of the public eye. Here, you can issue program challenges and “asks,” like reviewing a product or sharing their story about X, Y or Z. At the same time, it gives them a feeling of exclusivity and you a secure place to divulge your choice of information.

    A recognition or gamification system is a key best practice for an advocates program. It bubbles up top performers and confers a special status and identity for them.

    Leverage mission appropriate tools. Do you need a recommendation engine, social CRM system, a referral program, content syndication function, social sharing, survey capabilities or blog aggregation tools?

    Develop an engagement plan

    To help you balance the needs of the business in terms of content, product teams, marketing, etc., develop an engagement calendar to organize and schedule activities, announcements and “asks.” This allows you to offer your advocates a variety of content and opportunities to suit many needs, including your stakeholders. Below is an example of an engagement calendar—as you can see, it can be simple in design.

    clip_image002

    There isn’t a magic formula for how often you should engage. You don’t want to be overwhelming, but at the same time, you want to establish a regular cadence. It is best to refresh your content and engagement “asks” on a weekly basis at a minimum. Be flexible, as you may want to change up your activities or topics for a week based on advocate feedback. Be transparent and have real conversations with your advocates. Don’t come off as overly promotional—it is all about humanizing your brand.

    At the end of the day, engaging brand advocates is not an insurmountable task. You just need to be ready to commit to building and nurturing long-term relationships, pay off their needs and make it easy for them to do what they do best.

    Please leave a comment if you have any ideas or thoughts on engaging advocates. Part 3 of this blog series will focus on measuring advocate impact and influence. See you then!

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