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Bloggers and marketers alike are slowly getting their heads around the new Federal Trade Commission (FTC) guidelines for endorsements and testimonials. It's a simple formula, really:
Endorsement + Compensation = Disclosure Required.
Most bloggers are disclosing the relationship within the post or putting a disclaimer on the post, usually at the bottom. Many have also added editorial/disclosure policies to their blogs, which while not an FTC requirement, is definitely a best practice.
And responsible marketers are doing their part by reminding bloggers who get free product or cash from them to disclose the business relationship if/when they write about the product.
It's all good. Except when it comes to how to disclose on Twitter. That just seems to make everyone's head explode.
The FTC offers the following guidance in a new Q&A about the guidelines:
What about a platform like Twitter? How can I make a disclosure when my message is limited to 140 characters?
The FTC isn’t mandating the specific wording of disclosures. However, the same general principle – that people have the information they need to evaluate sponsored statements – applies across the board, regardless of the advertising medium. A hashtag like "#paid ad" uses only 8 characters. Shorter hashtags -– like "#paid" and "#ad" –- also might be effective.
The general complaint about this solution, which I have heard more than once at conference panels on which I have participated in the past year as a representative of Blog With Integrity, is that the shorter hashtag still takes up valuable characters and interrupts the conversation if it has to be included on every single tweet about the product or service.
Other critics (correctly) bring up the point that #ad or #paid is too broad a brush. It doesn't cover all the potential nuances of a relationship between a marketer and sponsored tweeter. As a result, "tagging" models have been proposed by members of the blogging community and commercial vendors, including a simple system proposed last summer by the folks at ZRecs and a more complex framework proposed by commercial firm CMP.ly. Commercial solution Sponsored Tweets (IZEA) automatically appends a disclosure to tweets.
The danger is that these systems become so complex that you'll need a dictionary to understand them. To get an idea of how absurd this could become, read BlogHer Contributing Editor debontherocks' post Alternative Hashtags for the Discerning Tweeter.
All kidding aside, if you need a lexicon to understand the label, the disclosure probably doesn't meet the FTC's general guidance that disclosure must be clear and conspicuous.
So what's a responsible sponsored tweeter to do? Here are some tips.
The best way to disclose is always in context, whether it's a blog post or a tweet: "Enjoying trip to WDW as guest of Big Swanky Company." "The beach at host hotel Swanky Resort is lovely." "Thrilled to be a guest of Consumer Products Company at their press event."
Hashtags like #sponsored #ad #paid are clear, so go ahead and use them if they work for your tweeting style. Don't use shorthand like #sp, which is NOT clear.
Just using an event hashtag -- even for a fully sponsored invitation-only event -- is probably not sufficient in and of itself, unless you are reasonably assured that everyone reading those tweets understands that it is a sponsored event for all attendees. My advice: Disclose in an initial tweet, so readers have context for your use of the hashtag. For example: "Am v. excited abt being BigCompany's guest at the #BigCoMtg in LA"
If you also are writing a post about the product, event or trip, you can put a short disclosure in the tweet and the longer disclosure in the post. For example, if you were sponsored by Marriott Hotels on a trip to Aruba, your post-trip tweet could be: "Our family trip to Aruba as guest
