Ever wonder if someone promoting a product is being paid to do so or truly loves the product? It can be either or both of these, but the nature of the relationship between the brand and the endorser isn’t always obvious. Material relationships between a brand and an endorser must be clearly disclosed. To make sure you’re properly and completely disclosing this information, the FTC has some endorsement guidelines to follow. Below is a summarized version of just some of the guidelines you should be aware of.
FTC Endorsement Guidelines:
Can employees of a company tout their products/services on their personal social channels?
Employees can elect to post on behalf of their company on their own accord but must disclose their employment relationship when making an endorsement.
- “Loving the new low-fat coffee creamer my company just launched.”
- “So proud of my employer for their dedication to supporting military families. See how you can get involved <link>”
Do influencers need to disclose they were given something for their endorsement?
Yes. Influencers must state within the body of their post or as a separate disclaimer what they received for their endorsement. Providing their readers with the essential information of what was received is effective and complies with FTC Guidelines.
- “Company X gave me this product to try.”
- “The products I’m going to use in this video were sent to me by Company X.”
- “Company X has compensated me for this post.”
- “This is a sponsored post through Company X.”
- For short-form environments like Twitter or Instagram, #sponsored, #promotion, or #ad can be used within Twitter where message length is limited.
What is the proper way for agency employees to engage with or post client content on personal social channels?
If employees elect to post content on their personal social channels or elect to use their personal channels to post/comment directly within their clients’ channels that mention, imply connection to or endorse a client, they must disclose their working relationship/connection. This can be done by using “#client” in the post or spelling out that they are a client. This also applies to any client endorsements posted to the agency social platforms.
- “My client is hosting a great event for xyz…” or
- “Can’t wait to attend this awesome xyz event tonight. #client”
- “Have you tried my client’s awesome new smoothie maker?”
Can you ask employees to spread social content about clients’ products/services?
No. Soliciting employees to promote or endorse clients on their social channels is against FTC guidelines. Employees can elect to post on behalf of clients on their own accord and must disclose their connection to the client as noted above.
For a complete listing of FTC Endorsement Guidelines visit: https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking
Jamie Gyerman is Associate Director, Optimization at AKHIA.