Social Advocacy – Opportunities and Responsibilities of Engaging your Employees and Advocates in Social Channels

1. Social Advocacy – Opportunities and
Responsibilities of Engaging your Employees
and Advocates in Social Channels
Tom Chernaik
CEO, CMP.LY

2. Our Mission
To protect consumers and lessen regulatory burdens on business
to create an open and transparent marketplace
• Simplify and standardize regulatory compliance and disclosures for businesses
to build brand trust with their consumers
• Create tools to effectively and efficiently manage, monitor and measure
marketing efforts
• Enables companies of any size scale meet regulatory and disclosure
challenges in the most efficient & cost effective manner
• Provides consumers with a memorable and easy to understand disclosure of
business relationships and practices
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3. Agenda
• Developing Trends
• Need For Disclosure
• Regulatory Landscape
• Agency Risks
• Updated WOMMA (US) Guidelines
• Disclosure Considerations & Challenges
• Why CMP.LY
• Eating Your Vegetables
• Measurable Insights

4. Developing Trends
• Increasing reliance on advocate networks
• Episodic campaigns giving way to ongoing efforts
• Direct relationships with brands
• Moving from traditional blogs across many channels
• Unprecedented sharing & syndication of content
• Employees, agencies and vendors as advocates
• Heightened public awareness
• Increasing focus of regulators
• Scale of programs is challenging
• Brands are concerned about trust, reputation & risk
• Even traditionally regulated businesses are engaging
• Larger budgets demand better measurement
• Brands are expecting the agency to handle it
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5. Need for Disclosure
• FTC: Endorsements/Testimonials; Material connection disclosures
• SEC: Antifraud; Compliance; Recordkeeping; Safe Harbor
• FINRA: Conflict of Interest Disclosures; Suitability Disclaimers
• FDA: Safety warnings; Fair balance information; Sunshine Act
• FEC: Political disclosures in short-form social channels
• OFT: UK Advertising Codes
• ASA: Revised CAP Code
• IPM/ISBA: Code of Conduct for Experiential Marketing
• Privacy: Privacy Notices
• Liability: Terms & Conditions; Offers; Contest Rules; Social Media Policies
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6. Notable Events
• FTC Guidelines (endorsements) December 2009
• FTC action(endorsements) April 2010
• FTC action (astroturfing) August 2010
• FTC action(affiliate marketing) March 2011
• FTC action (endorsements) November 2011
• State action (deceptive advertising) July 2009
• OFT action (UK) (endorsement) December 2010
• CAP Code Update (disclosure) March 2011
• Google Chrome (disclosure) January 2012
• ASA action (UK) (contests) January 2012
• ASA action (UK) (endorsement) March 2012
• FTC Workshop (disclosure) May 2012
• Class Action (disclosure) June 2012
• ASA action (UK) (endorsement) June 2012
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7. Risks of Non-Compliance
• Court of Public Opinion
– Consumers, bloggers,
– Social media backlash
– Blacklisting
• PR Nightmares
– Scandals, reports & investigations
– Bad press & negative opinions
• Regulatory Action / Investigations
– Significant legal costs
– Penalties and settlement terms
– Potential for erosion of brand trust
• Legal Exposure / Liability
– 3rd party lawsuits / consumer actions
– Responsibility for representatives
– Lack of documentation
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8. Agency Risk
Advertisers are responsible for the actions of their
agencies
• Social media policies must be in alignment
• Disclosure and monitoring must be considered
• Ask the right questions (subcontractors, vendors, platforms)
• Increasing regulation – FTC, OFT, ASA, FINRA, FDA, Sunshine Act
• Clients are expecting their agencies to lead these efforts
Key takeaways:Need to lead with and provide clients with social media best practices
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9. Updated WOMMA Guidelines
Draft released for public comments this week
• Confusion around responsibilities of various stakeholders (Advertisers,
Bloggers, Agencies, Vendors, Influencers)
• Monitoring for disclosure and for claims
• Syndication of content across channels
• New platform challenges
• Updated guidance from the FTC and other industry groups
• Definitions and nomenclature
– Advocate replaces Blogger
– Marketer replaces Advertiser
– Expand scope to encompass new platforms, programs and challenges
– Define areas of concern (non-monetary incentives, promotions, etc.)
• Includes areas of additional concern
• http://womma.org/ethicsreview/

10. Disclosure Considerations
• Platforms
• Programs
– Paid Review / Endorsement / Mentions
– Ambassador and Advocate Programs
– Sampling / Reviews / Gifting / Fly Aways / Haul Video
– Contests / Promotions / Special Offers
– Corporate Communications
– Social Media Policy Compliance
• Products
– Influencer Incentives
– Sponsored/Featured/Promoted Messaging
– Sharing/Signs of Approval on Social Platforms
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11. The Problem
How to
get this...
...into this
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12. Current Solutions
• Expect the agency to handle it
• Leave it up to the influencer
• Ad-hoc compliance solutions / hashtags
• Rely on background &profile disclosures
• Use site-wide disclosures
• Lack of monitoring
• Simply ignore it
Best intentions vs. Best Practices
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13. What About Hashtags?
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14. What About Hashtags?
• #AD
• #SPON
• #Endorse
What is wrong?
• No Context
• Not designed for use
• Tracking is limited
• Does not scale
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15. Simple Programs Can Be Complex
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16. Ad Hoc Compliance
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17. Ad Hoc Compliance
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18. Ad Hoc Compliance
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19. Managing Scale
6/3
6/13
7/8
9/1
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20. CMP.LY – Iconic Compliance Standard
Iconic Compliance Standard
Robust Compliance Management, Reporting & Documentation Tools
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21. CMP.LY – Disclosure Standard
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22. CMP.LY - Social Media & Microblogging
CMP.LY indicates that disclosure language applies & links to detail
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23. CMP.LY in Use – Disclosure
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24. CMP.LY In Use – One Link Solution
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25. CMP.LY In Use – Full Documentation
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26. CMP.LY In Use - Pinterest
Documented disclosure process
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27. CMP.LY In Use - Pinterest
Documented disclosure process
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28. CMP.LY - How it Works
Note: Additional for multi-user programs
1. Sign into your 2. Customize for 3. Invite participants into 4. Participants click
CMP.LY account, specific policy the program. through to sign up
select a program and language; add any and accept the policy.
disclosure type. appropriate notes. Acceptance is
Launch program. documented.
5. Participants receive 6. Participants posts 7. CMP.LY tracks the 8. CMP.LY generates
appropriate code social media content, codes for real-time alerts; creates 3rd
and/or badge including code/badge. analytics and party audit trail;
monitors influencer archives all data.
feeds for brand
names & keywords.
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29. Manage Program Alerts - Overview

30. Eat Your Vegetables

31. What You See Today

32. Measuring Ripples

33. Measuring The Splash

34. Measuring Third Parties

35. Program Overview
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36. Program Reach & Amplification
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37. Social Dashboard
Reach & Amplification Metrics

38. Twitter Dashboard

39. “It’s quick and easy, and
you can even do it on
micro-blogging services
such as Twitter.”
-Mashable
“Where there's a
challenge, there's
Tom Chernaik
probably a tech startup. CEO
Enter CMP.LY, which aims 646.369.4555
to make compliance
tom@cmp.ly
simple for the Twitter and
Foursquare users of the
world.” http://cmp.ly
-CNN Money
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