It can be a great marketing strategy, but make sure they are following these important FTC rules.
The Federal Trade Commission (FTC) continues to pay attention to how companies use influencers in their marketing. After settling charges in September 2017 against two individual social-media influencers prominent in the gaming industry, the FTC issued guidance for influencers touting brands in their social-media posts or blogs. A new brochure, Disclosures 101 for Social Media Influencers, summarizes that advice and gives tips on how influencers must disclose sponsorships to their followers.
The Right Way to Manage Influencers
Using social-media influencers can be a very positive and successful marketing tool for retailers and other dance businesses. For instance, a store or a dancewear maker might work with a local dance celeb or a ballet star who has a large social-media following as a “brand ambassador” to encourage dancers to shop at their store (or buy a brand’s leotard). While influencers themselves are responsible for making these disclosures, it’s helpful for any dance business to understand the guidelines.
It’s All About Truth in Advertising
The rules are meant to protect consumers—to make sure that your customers understand clearly the “material connection” (the relationship) between an influencer and a business, or between an endorser and any promoted product. “A material connection to the brand includes a personal, family or employment relationship,” according to the FTC, “or a financial relationship—such as the brand paying you or giving you free or discounted products or services.”
The FTC describes the basic premise this way:
“Suppose you meet someone who tells you about a great new product. She tells you it performs wonderfully and offers fantastic new features that nobody else has. Would that recommendation factor into your decision to buy the product? Probably.
“Now suppose the person works for the company that sells the product—or has been paid by the company to tout the product [or the person’s sister owns the company.] Would you want to know that when you’re evaluating the endorser’s glowing recommendation? You bet.”
Tips for Social-Media Influencers and Brand Ambassadors
Any material connection should be disclosed “clearly and conspicuously,” according to FTC rules. The new brochure summarizes FTC guidance from its Endorsement Guides and a 2017 question-and-answer document produced by staff, offering how-to tips. Here are a few:
- Don’t assume followers know about all your brand relationships, however obvious they may seem to you.
- Financial relationships aren’t limited to money. Disclose the relationship if you got anything of value to mention a product.
- Make sure any sponsorship or endorsement disclosure is hard to miss. For instance, don’t bury disclosures in a string of hashtags. Readers can easily skip over them.
- Don’t include disclosures in “about” sections or profile bios.
- Don’t rely on disclosures that people will see only if they click “more.” Instagram posts on mobile devices typically show only the first three lines of a longer post unless you click “more,” which many may not do. When making endorsements on Instagram, businesses should disclose any material connection above the “more” button.
- Use simple and clear language. The FTC suggests that 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.”
- Don’t use ambiguous disclosures like “Thanks [Brand],” #collab, #sp, #spon, or stand-alone terms like #thanks or #ambassador.
- On image-only platforms like Snapchat or Instagram Stories, superimpose disclosures over the images.
- For videos, include the disclosure in the video, not just in the description of the video.
The Bottom Line
Although it’s the responsibility of influencers themselves to understand and follow the FTC rules for endorsements and disclosures, as a business owner you’ll want to familiarize yourself with the rules and make them part of your working understanding with influencers you use. Get the brochure and share it with your brand ambassadors. The FTC website has more tips.