We’re continuing to share perspectives from WOMMA members on how their companies are incorporating and interpreting the new FTC guidelines.
Today, we hear from Steve Hershberger, ComBlu principal and co-founder. ComBlu designs and manages influencer marketing programs and brand-related communities, so the new guidelines from the FTC play a role in how ComBlu does business. Steve smartly riffs on three questions posed to him.
Q1: What concerns have your clients raised to you about the FTC requiring disclosure?
STEVE: “The alarming thing is that this topic has not been socialized enough through the brand management corridors at big brands, let alone smaller marketers and even agencies, with only a few exceptions. Nine times out of ten, this is a topic we bring up with clients and prospects as part of a strategic planning initiative or at least include in a deep dive landscape review. I am not yet convinced that marketers realize the business implications, including risk, that is involved in social media, which is why the adoption and adherence of standards and accepted best practices is so crucial.
Today, we still see the approach to social media risk, in this case, defined as paid endorsement and advocate claims as ad-hoc. In essence, it is either an after-thought or treated as someone else’s problem. The problem is that most marketers, unlike their counterparts in regulated industries such as financial services and healthcare haven’t yet experienced close up, what a regulating governmental body with a mandate is capable of doing.
Marketers cannot simply expect to open up the doors of social engagement and not apply discipline to their efforts. If they do so, even in ignorance to the regulations, it is a matter of time before something bad happens. Applying a set of social marketing guidelines that comply with the FTC guidelines is frankly, pretty straightforward, it’s really a matter of approach and process. There is really no excuse for not doing it, especially as time goes on that this topic becomes more and more visible.
Typically, we try and make it easy for clients by baking it into the approach we design for them and then train them as to the what and why. Part of our role over time is to make spot checks to ensure the best practices and standards become part of the natural process and culture of the organization behind the brand. We are not, nor want to be ‘hall monitors’ but do understand that doing things right doesn’t take much more effort the first time than simply winging it (if you have the right resources and team), after that, innovation and social marketing activities should even get easier!
When or if we get pushback, we have a conversation similar to the one I’ve outlined above. If they are not willing to adhere to a set of best practices and standards, we simply won’t work with them. The risk is too great.”
Q2: What steps is ComBlu taking in designing marketing programs to comply with the disclosure requirement?
STEVE: “We have built our social marketing processes, both planning and execution around a set of living best practices. Because of this, any of the programs our brands are involved in have the tools and approaches necessary to comply baked right in.
In some cases, it’s as simple as a series of check boxes built into program tools and planning guides. In other cases, we had to create tools for brand teams to use, such as a rewards spectrum guide that provides a spectrum of sample rewards from explicit (‘Here’s a laptop you can have to use in testing if you blog about my product. Oh, don’t worry about returning it.’) to implicit (‘Thank you for your help. We want to spotlight your work on in our community.’).
As part of our work, we do regular planning sessions, as does everyone else in our field. We track these activities and meet on the results, along with the more traditional social marketing metrics. Again, it’s not that hard if you approach it right.
It is important to have a well-defined and accessible set of social media guidelines that is available to both your employees and your customers. You should be able to tie the content and activity your brand is doing directly online and offline.
Lastly, we would also suggest quarterly meetings to ‘audit’ social media activities. This can be done simply by creating a social media best practices checklist and requiring your marketing teams to review planning documents, processes, activities, and resources to align with the items on the checklist. Self policing is better than mandatory policing (think Sarbanes-Oxley).”
Q3: Have you seen a best practice example of disclosure? If so, do share who is doing what and why you see it as a best practice.
STEVE: “A number of big brands are starting to do it well. Intel, Dell and Best Buy are three that come to mind. I think the biggest reason that Intel and Dell are doing well at it has to do with one key decision they have made. Both have set up centralized, cross-functional teams that are Centers of Excellence. These teams own the responsibility to set up, train, develop and deliver best practices approaches that hold brand teams and marketers accountable for both FTC compliance, as well as, delivering meaningful, true programs that deliver real value.
The good news is this approach is transformative. Marketing is changing for the better, this is a driver of that. So the short term pain is well worth the long term gain.”
More perspectives from WOMMA members on the FTC Guidelines to come …
