Achieving Social Media Actualization

Posted on December 15, 2010 by Comments Off

Over the past year, we’ve seen a shift in the way our clients are thinking about social media: namely, the conversations we are having today are less about WHY and more about HOW.

This is an important evolution. In the beginning stages of social media adoption, brands tend to be simply concerned with establishing a presence, tapping into the trend. In this phase, social media executions are chaotic, ad hoc — typically don’t accrue to anything. In pockets, processes and best practices begin to develop; however, in most cases, these practices tend not to be adopted consistently across the organization. Then, inevitably, come the ROI questions. To address the ROI question, organizations have to define standard business processes, examine objectives and map outcomes. 


It’s typically somewhere between maturation out of the ad-hoc phase and into the beginnings of process that companies begin to see the delta between the vision and the reality and come to us with the HOW questions.

  • How do we organize?
  • How do we prioritize?
  • How do we create and manage content?
  • How do we centralize measurement?
  • How do we establish and manage governance processes?

In our fourth post on the Influence Toolkit, we look at how our Social Influence System can help companies achieve the organizational structure, processes and governance to fully actualize on the promise of social media.

Many of the companies we speak to face a common challenge: social media is executed in silos with little integration or centralized management. From the audience perspective, the net result is a chaotic experience, with little engagement, often lacking in follow-through and inconsistency in messaging.

The solution starts with the establishment of a centralized governance body within the organization which is charged with social media governance — a Social Media Center of Excellence (SMCoE). This SMCoE team represents a unified integration point for internal stakeholders and also oversees content strategy, ensuring consistency in messaging, experience and engagement among external audiences.

Similar to a modern newsroom model, the SMCoE represents the editorial board and news hub at the heart of the operation. In this context, stakeholder orgs — such as PR, Marcomm, Business Units — are analogous to the news bureaus responsible for the creation of content. Content flows into the hub from the bureaus, where it is reviewed, packaged, published and managed.

Once the SMCoE team is in place, an organization is far better equipped to engage effectively on social media and achieve desired outcomes. Processes and workflows are adapted to suit the real-time demands of social media and governance roles are defined for efficient, actionable decision-making.

What this looks like from the outside is a brand that engages fluidly in conversation across social media channels. The brand builds its follower base organically and is able to drive narratives that are genuinely interesting and generate buzz. It participates in existing conversations in a way that is relevant. And if you engage the brand on one of its social media channels, it responds to your query or concern with the speed and authenticity that an individual would.

Has your company achieved social media actualization?

Does the Internet Make Us Dumber? Or Smarter? Or Both?

Posted on June 21, 2010 by 2 Comments

Over on my Facebook page I’ve been playing host to a weekend-long debate, which has evolved into a discussion worthy of it’s own blog post.

The question: Are we dumbing down as a culture? And if so, what role does media play?

Cited: 3 dueling op-eds

  1. Does the Internet Make You Dumber? WSJ, Nicholas Carr quotes the Roman philosopher Seneca: “to be everywhere is to be nowhere,” arguing that the hyperlinked structure of the internet contributes to a persistent state of distraction which, research indicates, hampers deep thought and, along with it, retention of information and absorption of knowledge.
  2. Mind Over Mass Media, NYT, Stephen Pinker argues that new forms of media have always caused panics (the printing press, newspapers, television, paperbacks), but such panics fail reality check. The oft-bemoaned perception that we are dumbing down as a culture is not supported by evidence to the contrary, such as the modern output of scientific innovation.
  3. Does the Internet Make You Smarter? WSJ, Clay Shirky references historical disruptions in culture fueled by new media evolutions (the Protestant Reformation, fueled by print) to illustrate the pattern of initial break-down of cultural/intellectual norms followed by an explosion of new creative outputs which raised societies to a new level.

The debate sub-streams

  1. To what extent does media contribute to the dumbing down of a culture? Or does it? Or is it the symptom of a dumbed down culture? Evidence to support the “dumbing down” hypothesis is seen in the insipidness of so-called “Reality TV,” the political and cultural extremes cultivated by and reinforced by news agendas (FOX) and the 24-hour news cycle, and the persistent distraction we suffer from as a result of our hyperlinked, short-form internet and social media behaviors. Does media fuel this, or is it merely a mirror reflecting the culture as it is? Or is it a distorted mirror, reflecting culture at the edges?
  2. Why are there so few culturally and politically meaningful comedians compared to two to three decades ago? Who are the Lenny Bruce, George Carlin, Richard Pryor of today? (John Stewart and Stephen Colbert of course…)  Is this evidence of a cultural dumbing down? Or is it evidence simply of the business-minded Hollywood machine which has optimized to produce pulp for the masses rather than the edges?
  3. And what about the role of education and critical thinking? One could argue that all three of the op-ed author’s arguments about the impact of the internet and social media on us as a culture are accurate — the internet, like all media, is simply an amplifier — widening the gap by which the dumb are becoming dumber, the smart, smarter. But isn’t it really an issue of critical thinking abilities and the willingness to apply them? Is this skill being taught more or less than a generation or two ago? (remember McCarthyism?) Does classical education or internet-enabled knowledge assimilation contribute more or less to one’s ability to absorb and [critically] process knowledge?

The meta: the medium is the message

Interestingly, the discussion is in many respects an example of “the medium is the message” at play:

  • Living room —> Web —> Facebook. The conversation originated in my living room as a wine-sotted debate between my husband and our neighbor, crossed over onto social media when I opened my laptop to hunt down the NYT op-ed as my contribution to the debate, then posted on Facebook.
  • Internet-facilitated connection of culturally and geographically dispersed nodes. Once on Facebook, the discussion then drew in an individual from my hometown (whom I hadn’t spoken to in 20-years, aside from him friending me on Facebook), my husband (sitting across the room from me debating with me on Facebook from his iPhone), a martial arts buddy from across the country and a couple work colleagues from opposite coasts.
  • Facebook’s alienation of “professional creators” via sketchy privacy and copyright policies. Meanwhile my neighbor exited the debate completely once he walked across the street and went home because, as a professional photographer, he wants nothing to do with Facebook and its questionable privacy and copyright issues.

So what do you think? Are we dumbing down as a culture? And does the internet and social media play a role?

5 Social Engagement Heuristics

Posted on June 17, 2010 by 2 Comments

When it comes to best practices for launching online communities and social sites, a few fundamentals come to mind: know your audience, develop a content strategy, dedicate appropriate resources to management and moderation, build optimization refreshes into your plan. This is the baseline.

However, drilling deeper into the execution process, how do we optimize the design, architecture and content strategy for social behaviors and user participation?

 The essential 10 usability heuristics are a start, but we recommend another five specific to social engagement:

1) Participation continuum. Even the most active communities are driven by content created by a minority of the audience base. Most of us are spectators. When designing your community, ensure that pages contain a gradation of participatory content types that ranges from read to share to create.

2) Purposeful content hierarchy. When creating a site that contains a blend of editorial and community content, it’s all too easy to run amok with mixed messages and content types and calls to action. The resulting experience for users is confusion and uncertainty as to what they should be doing or getting from the page. Even with a mix of content types, the intent of the page should be clear and cohesive, and primary content should be supported by — not at odds with — secondary and tertiary page content.

3) Participation-triggering. Pages should include both the functionality and content to support participation. This includes everything from basic functionality, such as including “tweet” this buttons, to more advanced functionality that allows users to rework editorial content, such as’s “recipe hack” feature, as well as incorporating contests and giveaways and even simply asking the question: “What’s your opinion?”

4) Peer relationship-building. If the objective is to create a community, ensure that pages contain structures that facilitate conversation and engagement between peers. This includes building in prompts to encourage members to build out their profiles.

5) Multiple access paths. This is a usability fundamental, but one that is much more important for social sites, which often have paths from editorial content to community sections but no path back.

SXSW Day 1: The Content Path

Posted on March 12, 2010 by Comments Off

SXSW Day 1, I took the content path. The three-panel series – which they called workshops (not sure I entirely agree with that nomenclature though) – boil down to this:


  1. You need a content strategy. Let me tell you why. Because words are cheaper than comps. Because a cohesive UX requires a conduit between the designers, the copywriters and the brand strategists. Because effective message delivery starts with a good message architecture. And because messages across channels become disjointed without an editorial calendar to ensure consistency and adherence to message goals. Also, you want a social media strategy? There is no social media strategy without a content strategy. Content strategy is core to conversation strategy. Passionately presented by Margot Bloomstein. See her slides here.
  2. Don’t be afraid of the scary spreadsheet, it’s here to help. Three streams of a product strategy are design strategy, technology strategy and content strategy. Content strategy is often the missing link. So how do you approach a content strategy? Four-stage process: discover, design, develop, deploy. The majority of the discussion dug into the details of what the discover process looks like (“a really scary spreadsheet!”) – both quantitative/get the facts and subjective/assess the quality. Overall, the panel contained a lot of good content, but at such deep detail as to be more suited for a handbook than a presentation. Hope Rachel and Karen make the slides available. In the meantime, my stream-of-consciousness notes are captured here.
  3. 90 percent of everything is crud. Particularly on the Web. Bah. According to Richard Ziade and Tim Meaney of Arc90, the state of publishing can be summed up by Sturgeon’s law. We are sacrificing quality for quantity. The art of composition – mise-en-scene in theater terms – has largely disappeared. The idea of assembling content around an editorial vision is also gone on the Web today. All content is created equal, so it just sort of streams by. And far from the concept of an ambient content stream that we dine upon, we are in fact haplessly gorging ourselves. Why? As noted in the NYT article about why people share articles, people crave shared experience. So where do we go from here? Richard presented a series of “hopeful signs” to counter Tim’s “issues,” but they were tentative at best. Whither the editor. I think I missed the revenge part … perhaps that came in the form of our midsession emergency evacuation? More details in my stream-of-consciousness notes here.

My two cents: Content strategy is mission critical on three levels: process/workflow, social media conversation-building, and user experience. The latter gets at Tim and Richard’s gripe with the direction content has been taking as print media collapses and content online becomes sliced into ever smaller pieces. It’s true that editorial curation is getting lost on the social Web, but I would argue that it is being replaced by tools that allow us to self-curate, or to select curators in the form of those influence multipliers that we choose to follow.

And we DO have the ability to control the flow through the pipes (though we sometimes forget). But we don’t have as much control over the aesthetic presentation of the content we consume. This is where I see the crux of the need – and the opportunity – for good content strategy. Not simply designing and filling the pipes, but structuring and packaging the experience of the content flow. Mise-en-scène.

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The Future of Digital Healthcare: The Intersection of Pharma, Physicians, Social Media, UX Design and Process

Posted on February 11, 2010 by 3 Comments

Last week I attended two panels on healthcare and social media – BDI’s Healthcare Social Communications Leadership Forum and a NY Social Media Week panel, Navigating Social Media & New Technology in Healthcare & Pharmaceutical Industries. Much of the discussion – in both panels – had to do with the need for community among patients, and the role pharma brands can play in helping to facilitate this; the nuances of content (tone and tenor; separating gems from garbage; processes to distribute from internal out); as well as a visceral chafing among those that are already embracing social media against any references to a campaign mindset.

The latter came up in discussions of both channels and ROI: The dominant POV among the BDI panel was that social media should be embraced at a fundamental level and insisting upon ROI as you would a traditional marketing campaign misses the point. That said, Marc Monseau of Johnson & Johnson did emphasize the point that he couldn’t have achieved any of what he’s implemented at J&J without strong executive support. Which is to say, the most exemplary social media leaders in the healthcare space are focusing their education and evangelizing efforts on hitting the right nuance, versus justifying the fundamental value.

Some of the key themes in more detail:

Social media requires processes. Marc Monseau of Johnson & Johnson spoke at length about this – internal evangelizing, gaining executive support and creating clear protocols around who and what can go out via social media. Social media is low cost of entry, but highly resource-intensive. However, many companies likely already have mechanisms in place (both traditional PR spokesperson processes as well as content development), in which case it’s just a matter of refocusing them. Michael Fleming of GlaxoSmithKline also touched on the need to transform internal processes: if you can’t fluidly share information internally, you’re disadvantaged against individuals outside the organization who operate at a different pace.

Social media is a mindset, not a campaign. When asked to define social media, the overall consensus of the panel was that social media is not about the technology or the tools, but a mindset of engagement and interaction. Many argued that the persistent question of ROI missed the point – that social media should be seen as a fundamental part of business operations, like a call center, versus a campaign.

Content is context. Content is king, but it’s the context within which it’s delivered that is paramount in this space. Patients aren’t suffering for lack of content – when they search for information online the problem isn’t that they can’t find it, the problem is not knowing what they can trust. Separating the “gems from the garbage,” as one of the panelists put it. (Along those lines, an interesting tool that came up in discussion is Pixels & Pills’ Health Tweeder – a visualization tool to give a perspective of the health-related issues on Twitter that most concern people.)

One big opportunity for pharma brands is to help by facilitating relationships between patients, creating structures for patient communities. The other opportunity gets back to processes; as Fleming pointed out, pharma brands have a tremendous depth of knowledge and relationships, but currently don’t have mechanisms in place to distribute that knowledge to the external world – not proprietary info, but info that would help patients make decisions toward living better lives. Given the changing landscape in which traditional marketing messages aren’t resonating, this is a huge opportunity for pharma to shift into a new role. Again, it means shifting out of a campaign mentality, and treating social media as more of a fundamental business operation.

Think physicians and HCPs aren’t interested in digital tools? Think again. Some stats: 60% of physicians either are currently using social media or want to be; 65% of physicians have smartphones; 9 out of 10 physicians say the Internet is a critical tool to their practice. Lance Hill of Within3 pointed out that, contrary to the perception that physicians don’t have time for social networking, physicians are very heavy offline networkers. So the social media platforms that are most successful at engaging physicians tend to be those that marry offline with online and include task-based tools. 

UX design and cost are key barriers to adoption of digitized healthcare. Beyond social networking is the broader issue of digitizing healthcare practices – and the extent to which the currently available tools are help or hindrance to the practice of medicine. Under a provision of the stimulus bill signed into law last year, physicians must adopt use of electronic health records (EHR) and comply with standards of “meaningful use” (which have yet to be defined). Jay Parkinson, MD and founder of healthcare-focused design firm The Future Well, noted that the barriers to adoption of these tools are twofold: cost and usability. The existing tools require physicians to make an upfront investment of $45,000 for a system with a clunky interface that works like Windows 95; this is not an incentive when the competition is paper – which is in fact very efficient. The current systems are designed to capture volumes of data for courts and billing systems. Which is to say, not designed for the user – physicians, who have no interest in mining data. Doctors are not slow adopters; they will do anything that has potential to make them more money. But the current electronic systems don’t make them more money, they cost them money. 


Engadget vs. Commenters: Who Runs the Show?

Posted on February 3, 2010 by 7 Comments

Engadget CommentsMy colleagues on our consumer team have an interesting discussion going regarding the Engadget vs. Gizmodo approach to blog comments. For those unaware, Engadget has temporarily disabled comments due to a recent spike in trollish behavior; Gizmodo has responded with a post pointing to the merits of its somewhat more complex tiered comment system. Gizmodo concludes with an observation that the drastic measures Engadget is taking speak to the sad state of Internet commentary – abusive loudmouths are getting the upper hand.

In explaining its position, Engadget notes: “Some of you out there in the world of anonymous grandstanding have gotten the impression that you run the place, but that’s simply not the case.”


The consensus my colleagues have come to – thus far – is generally that conversation is the essence of blogs. That it’s precisely this feedback mechanism that differentiates blogs from static news outlets. And that a strong community should self-moderate – if it doesn’t, then there’s a bigger problem than the individual rogues and trolls.

I think this also unearths a bigger discussion about the role of the blogger and the role of the readers within the context of social media. Is Engadget right in asserting that it’s the editors, not the readers, that run the site? Or as news gathering and social journalism open up the playing field, is the role of an editor more of a social curator?

Massachusetts to Senate Incumbents: Start Fueling Your Social Media Army Now

Posted on January 20, 2010 by 1 Comment

Yesterday Massachusetts shocked the nation by voting Uncle Teddy’s senate seat over to a Republican. Almost as shocking as blue Massachusetts going red (not unprecedented, of course — I myself was a Somervillian when we elected Mitt Romney as governor) was  how quickly a previously unknown candidate came from behind, closed the gap and surged into a strong lead. We’ve seen this before… most notably in the much-documented campaign of Barack Obama.

pa rum pum pum pum

And so, even before the polls were closed, many a pundit had called the race based on Scott Brown’s lead in social media fandom. To say that his use of social media channels won the race is a gross simplification. However, a more direct correlation can be made to the open and rallying stance with which Brown used the channels, relative to the more structured and reserved stance of Martha Coakley.

My colleague Joe Farren says it well over on the WE Crisis & Issues Management blog:

“I’ve often thought the campaign trail resembles a rock music tour. It moves quickly from city to city and the performer relies on a collection of power chords, fist pumps and over-exposed chorus lines to whip supporters into a genuine lather.”

This is one of the areas social media excels. Social media tools can be used for many things —  listening and monitoring public opinion, demonstrating transparency, disseminating content — but at its core, social media is about being social. It’s about delivering personality and authenticity, connecting with (not messaging to) others and — for the purpose of political and issue-based campaigns — galvanizing multitudes of individuals into action.

Social media also lends itself to insurgency — fueling a grassroots army. If you’re a long-shot candidate, social media is a no-brainer. If you are an incumbent or front-runner, you’d be wise to think more like an insurgent and begin fueling your social media army early.

Because if there’s one thing that’s certain, it’s that social media is going to be a critical tool in the campaign toolboxes of the 2010 mid-term elections.

The Social Media Race for Massachusetts Senate Seat

Posted on January 19, 2010 by 1 Comment

coakleybrownFor those watching the Massachusetts special election, a particularly interesting storyline is Republican candidate Scott Brown’s surge in the polls — in a traditionally blue state — mapped against the two candidates’ respective social media strategies.

Through grassroots tactics Brown has managed to leverage the simmering unease surrounding the healthcare debate to appeal to independent voters. Springboarding his campaign off of the pledge to be the 41st vote against national healthcare reform legislation, Brown rolled out his announcement with a Twitter hashtag: #41stvote. Martha Coakley is using social media tools as well, but she’s using them differently. The overall cadence of her campaign is more traditional, as the Boston Globe details, heavily targeting a select set of political influencers, expecting they will help get people to the polls.

Although media coverage (such as AdAge’s Coakley Ignores Obama’s Digital-Media Playbook in Massachusetts, and the WSJ’s Atwitter in Mass.: Brown’s Social Media Strategy Tops Coakley’s) positions Brown as the clear leader in social media, a study conducted by the Emerging Media Research Council paints a somewhat more nuanced story. Brown certainly has more Facebook fans (70,800 vs. 13,529) and Twitter followers (9,679 vs. 3,385), but the two candidates have produced a similar amount of content (with the exception of Facebook posts):

  • Tweets (since Jan. 1) Brown 142 vs. Coakley 144
  • Twitter followers Brown 9,679 vs. Coakley 3,385
  • Facebook posts (since Jan. 1) Brown 125 vs. Coakley 58
  • Facebook fans Brown 70,800 vs. Coakley 13,529
  • YouTube videos Brown 57 vs. Coakley 52
  • YouTube video views Brown 578,271 vs. Coakley 51,173

What’s notable isn’t whether the candidates are using the channels (because they both are), but how each is using social media channels. The hook here is the level of engagement and interaction the candidate is able to induce.

A few key details noted in the EMRC findings:

  • Social media extends visibility, and with it, name recognition. According to a Nov. 12 survey only 51% of voters had heard of Scott Brown; as of Jan. 14 his name recognition had surged to 95%.
  • Content drives engagement on Twitter. Brown sent twice as many news-related messages as Coakley, whereas Coakley retweeted followers’ messages twice as often as Brown and included more personal messages. The total volume of tweets was similar (142 vs. 144) but Coakley delivered less original content. EMRC reports that in previous races stronger user engagement tends to correlate to delivery of news announcements and calls to action, versus personal messages.
  • Follows and fans are only a means to an end; interactions are what count. Brown received 10.6 times more Facebook fan page interactions and views of uploaded videos on YouTube than Coakley. Brown supporters are twice as likely to interact with the Brown Fan page than Coakley supporters are to interact with the Coakley fan page.
  • Social networks make the local national. Coakley has a higher percentage of in-state Twitter followers (24% vs. 17%), however because of the nature of social networks, out-of-state followers can make just as much impact (as evidenced by the 2009 Virginia McDonnell/Deeds race). Both candidates have called on out-of-state supporters to make “get out the vote” calls.

Regardless of who wins the Senate seat, the takeaway here is one of nuance. It’s not enough to simply use the channels. It’s about using them well. Understanding the dynamics that drive influence and engagement online, creating compelling content and inducing engagement and action amongst supporters.

Will Tweet for Gum: The Medium May be the Message, But What is Trident’s Strategy?

Posted on December 21, 2009 by Comments Off

Heather Snow, Account Director, WE Studio D

Trident gum adTrident’s latest print ad — a full page in USA Today and the New York Times featuring tweets of Trident gum fans — has kicked off a bit of buzz in the Twittersphere. Rather, Mashable’s post on the ad has kicked off buzz. For social media aficionados, it’s a beautiful thing to see a brand so prominently integrating Twitter into a traditional media campaign — and a full-page one at that.

The message is simple and to the point: People like you like Trident. See? They say so themselves. And the integrated approach harnesses the unique strengths of each medium — focusing the creative around the transparency of Twitter, extended via the reach of traditional mass media.

But will it sell gum?

With this question in mind, I’d posit that the campaign is a good step in the right direction and that the approach has tremendous potential, but in execution it falls short of its potential on several counts:

It falls short of its potential to actively drive sales.

It falls short of its potential to create engagement.

It falls short of its potential to foster conversation.

It falls short of its potential to build ROI off its existing creative.

The difference between a truly impactful campaign and a merely interesting ad is channel integration and a single unifying big idea.

Here are a few things Trident could be doing differently:

Conversation. Trident’s approach to harnessing the transparency and peer endorsement of Twitter is great. But it misses the #1 point of social media. Conversation. It’s not enough to demonstrate that people are tweeting about Trident, the objective should be to foster, build and engage conversation around the brand, product or a branded initiative.

Integration. The ad integrates two channels, but it does so statically. Once consumers have seen the ad, then what? Is the intention that consumers will go out and start tweeting about gum? Initial response has been tweeting about the ad (not the gum) by marketers and social media junkies. Which is a nice by-product of any ad campaign, but marketers aren’t the target audience. If the objective is to build buzz on Twitter, Trident needs to give consumers something to tweet about. Create a hashtag campaign. Give them something to talk about. A cause, a give-away, a contest… something.

Idea. “The people have Tweeted.” What’s the idea here exactly? Why not apply the same frame (transparent peer endorsement), but build upon the creative concept Trident is employing in its broadcast run? Why not build on the “will work for gum” concept and build an integrated, interactive campaign that truly has legs? The notion of gum as value exchange is a plucky idea. The TV ad is goofy, but rolled out online as an interactive contest or buzz-building campaign, it could be a lot of fun.

“The people have Tweeted” isn’t a bad ad. It’s clever. It’s bold. But the emphasis is in the wrong place. And as it currently stands, it’s missing the elements that could make it a great campaign.

What the FTC’s New Guidelines Mean for Marketers and Bloggers

Posted on December 14, 2009 by Comments Off

Heather Snow, Account Director, WE Studio D

FTC Word CloudThe Federal Trade Commission (FTC) has released a new set of guidelines on advertising and endorsements, updating guidance to address use of social media influencers. These guidelines went into effect on December 1.

Sentiment in the blogosphere ranges from favorable to indignant. On the one hand, transparency is already considered a best practice, among the more reputable and widely read bloggers anyway. On the other, the guidelines effectively hold bloggers to a higher standard than traditional media, as Paul Holmes notes in a recent post on the subject. Never has there been a regulation forcing mainstream reporters to indicate free products received for review – the policy to accept or not accept free review products has always been at the discretion of the outlet. That said, many media outlets do have established policies, such as the New York Times’ Ethics in Journalism guide.

The spirit of the FTC’s new guidelines stems from concerns over disingenuous use of evolving social media tools, as noted by AdWeek – practices such as “astroturfing” and use of fake blogs. It is the consumer that’s at the heart of the guidelines, not the blogger. But in drawing new standards for bloggers without addressing traditional journalists, the FTC makes a distinction between “professional” journalists and bloggers.

The FTC dubs bloggers “endorsers,” and as such treats bloggers more in line with celebrity spokespeople than traditional journalists. This has to be due to an emphasis toward advertising practices, rather than PR.

In PR of course we see the distinction as much more fuzzy, particularly as traditional journalists join the ranks of bloggers. But lacking the gravitas of a media brand to ensure adherence to a set of professional standards – as well as a legacy, albeit eroding, of “church and state” policies – the distinction between journalists and “everyday” bloggers isn’t completely unfounded.

So what do these changes mean for us as marketers?

From a transparency best practices standpoint, the guidelines are common sense. But from a procedural and liability standpoint, they necessitate a few changes in the way marketers work with bloggers and other influencers in the social media realm, and vice versa.

Here’s the gist of the changes:

  • Liability and Expectations. The new guidelines hold both brands and endorsers liable for false or unsubstantiated claims or for failure to disclose the material connections. However, what this means in practice is more nuanced. The FTC will evaluate discretions on a case-by-case basis and would determine action, if any, based on the marketers’ best efforts to advise endorsers of their responsibilities and to monitor their coverage and online behavior.
  • Endorsements. The FTC considers bloggers, consumers engaged in word-of-mouth marketing programs and celebrity spokespeople all “endorsers” IF they speak or write favorably about a product or brand after having received payment (even in the form of free product). If a blogger receives a free product to review, it should be disclosed. The FTC now holds both endorsers and marketers liable for failure to disclose material connections. Best practice for marketers: outline a brief disclosure policy and share with all bloggers, consumer advocates and celebrity spokespeople with whom you engage in a formal marketing program and execute a formal monitoring program to ensure compliance.

  • Product Reviews and Disclosure. But what about review units sent with a formal loan agreement? This is where the guidelines get murky. However, transparent disclosure is always a best practice. Many high-profile bloggers already do disclose that they have received a review unit from the manufacturer. What changes is that the onus is now on the manufacturer to ensure disclosure.

  • Substantiation and False Claims. The FTC guides now hold both marketers and endorsers liable for false or unsubstantiated claims. It is the FTC’s view that if endorsers are receiving payment (even in the form of a product), they should bear the burden of familiarizing themselves with the product such that their claims are not false (even in instances that celebrity spokespeople are reading from a script). Best practice for marketers: outline a brief substantiation policy outlining the endorser’s responsibility to familiarize him or herself with the product prior to writing or speaking about it.

  • Endorsements on Twitter. Although the FTC doesn’t detail specific scenarios for addressing disclosure of endorsements on sites such as Twitter in which space is restricted, the expectation for disclosure still stands. An evolving set of approaches to address disclosure in Twitter include a mini-URL service provided by and adding the text “sponsored post” or “#ad.”

FTC twitter ex1

FTC twitter ex2

  • Employee Endorsements on Social Networks and Forums. The FTC also calls out social media endorsements on the part of a brand’s employees as a practice requiring disclosure (e.g., employees posting on a community forum should disclose their relationship with the manufacturer when participating in conversation). This would also apply to employees of agencies representing the brands. Best practice for marketers: implement a social media policy outlining protocol for employees to disclose their relationship to the brand when making endorsements in social media.

The FTC goes on to detail a number of examples to help reduce ambiguity. To go straight to the source, the Dec. 1 FTC guide can be found here.

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