The document discusses FTC guidelines regarding disclosure of relationships between bloggers/influencers and brands. It notes that bloggers must disclose any compensation or gifts received for reviews or endorsements. It provides examples of how brands like Ann Taylor LOFT must ensure bloggers disclose sponsorships to avoid deceptive practices accusations from the FTC. The document aims to educate PR professionals and bloggers on their disclosure responsibilities under FTC guidelines.

1. FTC
Guidelines
Overview:
How
it
Impacts
PR
and
the
Blogger
World
Sarah
Evans
@PRsarahevans
sarah@sevansstrategy.com
www.sevansstrategy.com

2. Disclose.
Disclose.
Disclose.
Official
FTC
Media
Release:
h2p://www.7c.gov/opa/2009/10/endortest.shtm
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

3. Why?
• It’s
the
right
thing
to
do
• You
want
readers,
brands
and
consumers
to
trust
you
(as
a
blogger
or
a
business)
• If
you’re
the
“owner”
of
the
brand
or
business,
you’re
ulHmately
responsible
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

4. Top
3
Takeaways
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

5. AdverHsements
that
feature
a
consumer
and
convey
his
or
her
experience
with
a
product
or
service
as
“typical”
are
required
to
disclose
the
results
consumers
can
generally
expect
What
does
that
mean?
Endorsements
must
be
truthful,
not
misleading.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

6. If
a
company
refers
in
an
adverHsement
to
the
findings
of
a
research
organizaHon
that
conducted
research
sponsored
by
the
company,
the
adverHsement
must
disclose
the
connecCon
between
both.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

7. A
post
by
a
blogger
who
receives
cash
or
in-­‐kind
payment
to
review
a
product
is
considered
an
endorsement.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

8. “The
FTC
guidelines
are
about
decepKve
pracKces
in
which
what
appears
to
be
an
honest
opinion
is,
in
fact,
a
biased
perspecKve.”
–
Joe
Chernov
(@jchernov),
co-­‐chair,
WOMMA
Ethics
CommiVee
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

9. TOOL:
FTC
Online
Endorsement
Guidelines
Quick
Overview
hVp://www.slideshare.net/PRsarahevans/Yc-­‐overview-­‐for-­‐online-­‐endorsements
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

10. On
behalf
of
the
brand…
• It’s
the
brand
or
adverHser’s
responsibility
to
inform
campaign
parHcipants.
UlHmately,
YOU
are
responsible.
Explain
to
members
of
your
network
what
can
–
and
can’t
–
be
said
about
the
product;
• Set
up
a
reasonable
monitoring
program
to
check
out
what
your
people
are
saying
about
your
product;
and
• Be
proacHve.
Follow
up
if
you
find
quesHonable
pracHces.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

11. TUDY
CASES
Ann
Taylor
LOFT
To
promote
the
launch
of
its
summer
collecHon,
Ann
Taylor
LOFT
invited
bloggers
to
aVend
an
exclusive
preview
of
its
2010
summer
collecHon.
"Bloggers
who
aVend
will
receive
a
special
giY,"
the
invitaHon
read,
"and
those
who
post
coverage
from
the
event
will
be
entered
in
a
mystery
giY
card
drawing
where
you
can
win
up
to
$500
at
LOFT!"

12. In
small
print
on
the
invitaHon:
"Please
note
all
bloggers
must
post
coverage
from
our
event
to
their
blog
within
24
hours
in
order
to
be
eligible.
Links
to
post
must
be
sent
to
[e-­‐mail
address],
along
with
the
code
on
the
back
of
your
giY
card
distributed
to
you
at
the
event.
You
will
be
noHfied
of
your
giY
card
amount
by
February
2.
GiY
card
amounts
will
vary
from
$10
to
$500."

13. “We
were
concerned
that
bloggers
who
aLended
a
preview
on
January
26,
2010
failed
to
disclose
that
they
received
giYs
for
posHng
blog
content
about
that
event,”
Mary
Engle,
the
FTC’s
associate
director-­‐
adverHsing
pracHces,
wrote
in
a
leVer
dated
April
20
to
Ann
Taylor’s
legal
representaHon.

14. The
ResoluCon?
• The
FTC
ulHmately
determined
not
to
recommend
an
enforcement
acHon,
because,
in
part
‘LOFT
adopted
a
wriVen
policy
.
.
.
staHng
that
LOFT
will
not
issue
any
giY
to
any
blogger
without
first
telling
the
blogger
that
the
blogger
must
disclose
the
giY
in
his
or
her
blog.’
• They
expect
the
company
to
monitor
bloggers’
compliance
with
the
obligaHon
to
disclose
giYs
they
receive
from
LOFT.”
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

15. On
behalf
of
the
blogger…
• It’s
the
brand
or
adverHser’s
responsibility
to
inform
you.
However,
it’s
your
responsibility
to
familiarize
yourself
with
online
endorsement
guidelines.
• Set
up
an
online
disclosure
policy
page
on
your
site
and
refer
to
disclosures
when
talking
about
the
product(s).
• Be
proacHve.
Push
back
on
the
brand
if
you
have
quesHons.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

16. Example
of
Blogger
Ambassador
Program:
Typical
“Asks”
• Get
the
tools.
Purchase/use/download
product.
• Join
the
Ambassador
Program
for
a
period
of
<insert
Hme
frame>.
• Use
our
product.
Use
the
product
and
document
your
experience.
• Create
content.
Post
a
blog
or
vlog
review
of
product
on
your
blog
or
website
(disclose
compensaHon)
• Social
sharing
of
the
review
post,
including:
at
least
one
tweet
and
one
share
on
Facebook
(disclose
compensaHon)
• Follow
brand
TwiVer
account
• Like
brand
Facebook
page
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

17. As
a
blogger
you
should
have
the
following:
• Disclosure
policy
on
blog
or
website
• Disclosures
you
use
when
sharing
informaHon
on
social
networks
• DocumentaHon
of
your
partnership
with
the
brand
Don’t
worry,
I’ll
show
you
what
these
look
like.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

18. An
exciHng
round
of
#True
or
#False.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

19. True
or
False?
A
comprehensive
online
disclosure
policy
on
your
website
fully
covers
you.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

20. FALSE
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

21. Tweet-­‐ready
You
must
disclose
your
affiliaHon
with
a
company
or
product
on
your
site
and
social
networks.
#BBsummit11
#FTC
via
@PRsarahevans

22. True
or
False?
If
a
restaurant
“comps”
you
a
meal
without
you
asking
for
it
and
you
write
about
them,
you
don’t
need
to
disclose.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

23. FALSE
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

24. True
or
False?
Adding
the
hashtag
#spon
to
your
tweet
covers
the
acknowledgement
that
you
were
compensated
in
some
way
for
your
post.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

25. TRUE
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

26. A
Few
Guidelines
Official
WOMMA
Guidelines
Others
• #spon
–
Sponsored
• #ad
• #paid
–
Paid
• #client
• #samp
–
Sample
• #advisoryboard
More
info
here:

27. Incorporated
hashtag
into
Google+
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

28. True
or
False?
Bloggers
not
in
compliance
with
guidelines
may
be
fined
up
to
$11,000.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

29. FALSE
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

30. There
is
no
fine
for
bloggers
for
not
complying
with
an
FTC
guide.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

31. True
or
False?
You
do
need
to
disclose
if
you
review
a
product
and
then
returned
it
to
the
business.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

32. DEPENDS
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

33. In
this
instance,
yes:
If
you
are
given
the
use
of
a
product
for
an
extended
amount
of
Hme
you
should
disclose:
1)
That
you
were
given
the
product;
2)
How
long
you
were
given
the
product;
and
3)
You
returned
the
product.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

34. Disclosure
Policy
Example
for
blog
or
website
This
policy
is
valid
from
July
14,
2011
This
blog
is
a
personal
blog
wri2en
and
edited
by
me.
For
quesKons
about
this
blog,
contact
<insert
your
email
address>.
This
blog
does
not
accept
any
form
of
cash
adverKsing,
sponsorship
or
paid
topics.
However,
we
will
and
do
accept
and
keep
free
products,
services,
travel,
event
Kckets
and
other
forms
of
compensaKon
from
companies
and
organizaKons.
The
owner(s)
of
this
blog
will
never
receive
compensaKon
in
any
way
from
this
blog.
This
blog
does
contain
content
which
might
present
a
conflict
of
interest.
This
content
may
not
always
be
idenKfied.
We
are
employed
or
consult
with:
Company
1,
Company
2,
etc…
We
serve
on
the
following
corporate
or
non
profit
boards:
Example
1,
Example
2,
etc…
We
are
acKve
in
a
poliKcal
party
which
influences
our
blog:
AffiliaKon
1.
We
blog
about
people
to
whom
we
are
related.
These
people
include:
My
mom
(name).
We
have
a
financial
interest
in
the
following
that
are
relevant
to
our
blogging:
Investment
1.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

35. TOOL:
DisclosurePolicy.org
hVp://disclosurepolicy.org/generator/generate_policy
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

36. True
or
False?
PracCcal
example.
A
company
with
a
new
app
hires
you
as
part
of
an
ambassador
program.
As
part
of
your
requirements
they
ask
you
to
submit
a
posiHve
review
in
an
app
store
along
with
“posiHve
comments.”
If
you
use
the
app
and
like
it
you
do
not
have
to
disclose
you
were
compensated.
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

37. FALSE
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

38. TOOLS
• Comp.ly
• WOMMA
• DisclosurePolicy.Org
• FTC
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

39. FTC
Resources
• Specific
quesHons:
Email:
endorsements@Yc.gov
• Revised
Guides
offer
more
than
35
examples
of
how
guidelines
apply
in
pracHcal
sesngs
• To-­‐the-­‐point
video
clips
• To
file
a
complaint
or
get
free
informaHon
on
consumer
issues,
visit
Yc.gov
or
call
toll-­‐free,
1-­‐877-­‐FTC-­‐HELP
(1-­‐877-­‐382-­‐4357)
#BBsummit11
www.sevansstrategy.com
@PRsarahevans

40. QuesHons?
#BBsummit11
www.sevansstrategy.com
@PRsarahevans