An Open Letter to WOMMA, IBNMA and the FTC
There has been a great deal of discussion regarding disclosure and compensation in social media marketing over the past few years. The discussion has evolved with the space and I believe that IZEA has been a catalyst for this ongoing refinement. While the industry still has work to do we have clearly defined some principles we all believe in:
Value is Value
Whether a blogger is compensated in cash, product, service, gift card or experience there is value being exchanged.
Disclosure is Required
When any value is exchanged between a blogger and marketer it should be disclosed to the reader.
IZEA fully agrees with the principles above. We have done our best to move the industry forward and refine our own business practices over time. We were the first company to require disclosure in our TOS, created the first Disclosure Policy in the blogosphere, created the first in-post Disclosure Badges and most recently became the first company to offer a fully automated Disclosure Audit.
The Problem with Our Industry
I was recently chosen as one of a handful of influencers to attend a blogger tour of a Fortune 100 company. While there, a marketing executive spoke about a marketing campaign in which bloggers where provided gift cards that tied to a promotion they were running. I asked the executive if the bloggers were required to disclose they received the gift cards, to which they replied “yes, full disclosure”. I tried to press the issue, but it became clear to me that disclosure is very subjective in social media marketing.
What is “Full Disclosure”?
What does full disclosure mean exactly? Does that mean the person has a site wide disclosure policy? Does it mean that they disclosed in the post? At the top or the bottom? In the title or body? Was it in bold or a special color? What did the text actually say?
The fact is that every agency, brand and blogger is operating by their own standards for “full disclosure”. Everybody is playing by a different set of rules with people pointing fingers at each other for what they believe is sub-standard.
How do you Enforce Disclosure?
Let’s assume that all bloggers were instructed by companies to disclose value exchanges in the same manner. How do you systematically enforce such disclosure? How do brands track that bloggers have complied with their request? How can brands legally protect themselves? The majority of brands and agencies never follow up on disclosure and if they do it is often too late.
Universal Disclosure Registry
I believe we should create a Universal Disclosure Registry. Here’s how it would work:
- Marketers would join the site and agree to a universal code of ethics (modeled after WOMMA Code of Ethics).
- Each campaign executed by the marketer would be registered in the system by the marketer.
- Each campaign participant would be registered by the marketer and a unique ID would be generated.
- Marketers can log into the system at any time to check on disclosure compliance. Compliance would be audited by machine verification of a code snippet.
- Bloggers would register with the site and agree to a universal code of ethics.
- Bloggers use the ID code provided by the advertiser to register their campaign participation.
- Bloggers would be provided with a snippet of code that they have to embed in their blog post, status update etc.
- Readers can research campaigns by clicking on the disclosure to find out which marketer initiated the campaign and which bloggers are participating.
- Readers can report campaigns that are not properly disclosed.
- We have already implemented our own version of a Universal Disclosure Registry at IZEA and it works.
Every post done through SocialSpark has standardized machine readable disclosure and automated disclosure audits. You can’t get paid through SocialSpark without having a disclosure badge.
What if all marketers and bloggers played by these same rules? What if we defined disclosure together and enforced it through an independent third party service run by a trade organization? I believe we can. Standardization of our practices through software automation and validation is the ultimate answer. I hope that one of our trade organizations takes the lead to make this happen.
I am committed to standardizing disclosure. IZEA will be happy to provide software development services to any trade organization that wants to own this effort moving forward.