Disclosures 101
Social Media
Influencers
for
Disclosures 101 for Social Media Influencers
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Do you work with brands
to recommend or endorse
products?
If so, you need to comply with the law
when making these recommendations.
One key is to make a good disclosure
of your relationship to the brand.
This brochure from FTC sta gives tips on
when and how to make good disclosures.
The FTC works to stop deceptive ads, and its Endorsement Guides
go into detail about how advertisers and endorsers can stay on the
right side of the law.
If you endorse a product through social media, your endorsement
message should make it obvious when you have a relationship
(“material connection”) with the brand. A “material connection” to
the brand includes a personal, family, or employment relationship or
a financial relationship – such as the brand paying you or giving you
free or discounted products or services.
Telling your followers about these kinds of relationships is important
because it helps keep your recommendations honest and truthful,
and it allows people to weigh the value of your endorsements.
As an influencer, it’s your responsibility to make these disclosures,
to be familiar with the Endorsement Guides, and to comply with laws
against deceptive ads. Don’t rely on others to do it for you.
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When to Disclose
⊲ Disclose when you have any financial, employment, personal,
or family relationship with a brand.
» Financial relationships aren’t limited to money. Disclose the
relationship if you got anything of value to mention a product.
» If a brand gives you free or discounted products or other perks
and then you mention one of its products, make a disclosure
even if you weren’t asked to mention that product.
» Don’t assume your followers already know about your
brand relationships.
» Make disclosures even if you think your evaluations
are unbiased.
⊲ Keep in mind that tags, likes, pins, and similar ways of showing
you like a brand or product are endorsements.
⊲ If posting from abroad, U.S. law applies if it’s reasonably
foreseeable that the post will aect U.S. consumers. Foreign laws
might also apply.
⊲ If you have no brand relationship and are just telling people about
a product you bought and happen to like, you don’t need to
declare that you don’t have a brand relationship.
Disclosures 101 for Social Media Influencers
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How to Disclose
Make sure people will see and understand
the disclosure.
⊲ Place it so it’s hard to miss.
» The disclosure should be placed with the endorsement
message itself.
» Disclosures are likely to be missed if they appear only on an
ABOUT ME or profile page, at the end of posts or videos, or
anywhere that requires a person to click MORE.
» Don’t mix your disclosure into a group of hashtags or links.
» If your endorsement is in a picture on a platform like Snapchat
and Instagram Stories, superimpose the disclosure over the
picture and make sure viewers have enough time to notice and
read it.
» If making an endorsement in a video, the disclosure should be
in the video and not just in the description uploaded with the
video. Viewers are more likely to notice disclosures made in
both audio and video. Some viewers may watch without sound
and others may not notice superimposed words.
» If making an endorsement in a live stream, the disclosure
should be repeated periodically so viewers who only see part
of the stream will get the disclosure.
@
Thanks to Acme brand for the free product!
#AcmePartner #ad
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⊲ Use simple and clear language.
» Simple explanations like “Thanks to Acme brand for the free
product” are often enough if placed in a way that is hard
to miss.
» So are terms like “advertisement,” “ad,” and “sponsored.”
» On a space-limited platform like Twitter, the terms
“AcmePartner” or “Acme Ambassador” (where Acme is the
brand name) are also options.
» It’s fine (but not necessary) to include a hashtag with
the disclosure, such as #ad or #sponsored.
» Don’t use vague or confusing terms like “sp,” “spon,” or
“collab,” or stand-alone terms like “thanks” or “ambassador,”
and stay away from other abbreviations and shorthand
when possible.
⊲ The disclosure should be in the same language as the
endorsement itself.
⊲ Don’t assume that a platform’s disclosure tool is good enough,
but consider using it in addition to your own, good disclosure.
Disclosures 101 for Social Media Influencers
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What Else to Know
⊲ You can’t talk about your experience with a product you
haven’t tried.
⊲ If you’re paid to talk about a product and thought it was terrible,
you can’t say it’s terrific.
⊲ You can’t make up claims about a product that would require
proof the advertiser doesn’t have – such as scientific proof that
a product can treat a health condition.
