有影响力的营销专业人员应遵守的FTC社交媒体指南是什么？金博宝188备用网址

在过去几年中，随着社交媒体和影响者营销的迅速扩展，FTC表示担心赞助的影响者和名人职位缺乏金博宝188备用网址透明度。他们已经发布了有关该主题的一系列社交媒体指南，以使事情变得更加清晰。

FTC指南实际上并不是全部新事物，至少对营销人员来说，它们当然不应该震惊。早在2000年5月，就互联网广告发布了第一个FTC指南 - 就互联网而言，石器时代很积极。

Over the “noughties” decade, celebrity endorsement started to become more common online. This was also the decade that saw the arrival of social media; Facebook, for instance, was created in 2004. So it is no surprise that the FTC recognized this with an updating of the FTC Endorsement Guidelines in 2009.

Since then the FTC has taken on a couple of big cases (Sony in 2014, and Xbox and Machinima in 2015 are particularly relevant) and as a result of these, the FTC further updated their Endorsement Guidelines in 2013 and 2015. The FTC has continued to monitor the situation, paying particular attention to both Lord & Taylor and Warner Brothers in 2016.

Despite these high publicity cases, until recently there has not really been any concerted efforts by brands and influencers to abide by the FTC Social Media guidelines. Most people played a “wait and see” game before they actively tried to put the guidelines into practice.

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What are the FTC Social Media Guidelines?

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FTC提醒影响者和营销人员的义务

In April 2017 the FTC decided to be more proactive and sent out letters to 90 influencers and marketers, reminding them that they should clearly and conspicuously disclose any relationships they have with brands when they endorse products on social media. These letters were written due to complaints to the FTC by various organizations who were concerned about the lack of transparency and honesty in some social media posts.

This is the first time that the FTC has directly tried to educate the influencers themselves.

它具有启动影响者行为的变化的作用。这可能是因为针对最初的90个影响者和营销人员并特别清楚其披露期望，他们将整个行业都唤醒了。尽管FTC尚未公开命名他们将信件发送给的人，但这些人显然改变了他们的发布行为，这对其他影响者和营销人员产生了流动效果。

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费尔节煽动了不满的火焰

应该在2017年4月和5月举行的灾难性的Fyre节，并在Instagram上大力推广肯德尔·詹纳（Kendall Jenner），贝拉·哈迪德（Bella Hadid），艾米丽·拉塔科夫斯基（Emily Ratajkowski）等名人，也对人民对影响者帖子的看法也产生了影响。。相当多的人认为这个音乐节确实得到了这些著名的名人的支持，他们没有意识到他们因促销活动而获得报酬。

It probably wouldn’t have been a problem if the festival had gone as planned, however, it instead turned into a total disaster - a highly expensive disaster from the viewpoint of those who bought tickets. Many of these out-of-pocket people turned their sights on the people they had relied upon, for what they had thought were genuine endorsements.

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Instagram’s Reaction to the Change in Attitude

Instagramwas specifically highlighted in the FTC’s letter. In particular, the letter addressed the problem that Instagram users with mobile devices usually only see the first three lines of post, and to see any extra they have to click on a “More” link. The reality is that most Instagram users are mainly interested in the pictures, and often don’t bother to click on the “More” link, so they miss anything an influencer may write about a post being sponsored if they position it later in the message.

The FTC was also concerned that there was no standard hashtag for a sponsored post, and as a result, users may not understand, even if the influencer has made a disclosure.

当我们报道InstagramPaid Partnership Feature - Everything You Should Know, Instagram has now made it easier to disclose paid arrangements between influencers and brands. The idea is that if there is any form of arrangement between an influencer and an advertiser then any relevant posts should be given a “Paid Partnership with…” sub-header (where the location tag is).

This avoids any problems of inconsistent hashtags being lost “below the fold” in a post.

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What are the Expectations of the FTC Social Media Guidelines?

The FTC guidelines are publically available in the FTC Endorsement Guides at theUS Government Publishing Office website。联邦贸易委员会通过指导的状态开始lines clear, with the first paragraph stating, “The Guides in this part represent administrative interpretations of laws enforced by the Federal Trade Commission for the guidance of the public in conducting its affairs in conformity with legal requirements.”

The overall name of the document is, “Guides Concerning Use of Endorsements and Testimonials in Advertising”, so not all parts of the guides are relevant to social media endorsement.

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FTC定义和一般考虑

They define endorsement as being “any advertising message (including verbal statements, demonstrations, or depictions of the name, signature, likeness or other identifying personal characteristics of an individual or the name or seal of an organization) that consumers are likely to believe reflects the opinions, beliefs, findings, or experiences of a party other than the sponsoring advertiser, even if the views expressed by that party are identical to those of the sponsoring advertiser.” This definition, although cumbersome, clearly means that when an influencer includes any form of a promotion for products or services in their posts/videos/pictures they are technically acting as an endorser for that product.

但是，重要的是要记住，在这里被认为是认可者，必须给予影响者某种形式的利益。如果您在没有收到任何回报的情况下对产品发表评论或进行审查，则不仅仅是认可。

FTC将专家定义为“由于经验，研究或培训，对特定主题的知识而具有的个人，团体或机构的知识优于普通人通常获得的知识”。现实是，许多有关特定主题的社交媒体影响者将符合FTC成为专家的定义。

Most of the examples in the definition section of the guidelines refer to traditional forms of advertising but there is one example showing how the FTC views online influencers in terms of whether they are endorsers. In this example, they talk about a consumer who buys a new brand of dog food and writes about how it has improved her dog’s health in her blog. They give three possible scenarios:

1. 博主支付食物,喜欢它,和普莱斯es it in her blog - not endorsement
2. The blogger gets the food for free because she was able to use a loyalty coupon from her local supermarket - not endorsement
3. The blogger receives free dog food through a network marketing scheme and writes a positive review of it - an endorsement

The guidelines make it very clear that endorsements must reflect the honest opinion of the endorser, and that they don’t make any claims that would be considered deceptive if the advertiser made them directly. This is particularly relevant in traditional advertising which quotes experts - the quote cannot be taken out of context and twist what the expert believes.

An online influencer has to be careful that they don’t mislead their audiences with untruthful statements. The guidelines give an example of a campaign for skin care products using influential beauty bloggers where the advertiser asks the bloggers to try out a new body lotion and write a review on the product. Suppose that a blogger independently claims in her review that the lotion cures eczema and recommends it to her readers who suffer from the condition. In this situation, both the blogger and the advertiser (even though the advertiser never made the claim) are liable for making unsubstantiated representations about the lotion.

Although advertisers won’t necessarily know what bloggers (or other social media influencers) are going to say about their products, the FTC makes it clear that advertisers have a responsibility to monitor posts and halt any continued false claims being made as soon as they notice any problems.

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Consumer Endorsement

This section of the guidelines mainly looks at businesses that include consumer endorsement in their ads. It does, however, make it clear that if a consumer is paid to give their experience of using a product, and he or she is depicted as being a typical user, then other users should also experience similar results.

The section emphasizes though, that these endorsement rules only apply if money (or product) changes hands. If three people review a movie (and haven’t been paid by the movie company or theaters) and give views that are different from most people, then there's no problem.

该准则还强调，消费者不是专家，因此，例如，您不能简单地为声称可以治愈秃头的产品提供证明，而不表现出科学证据。

这里涵盖的另一个区域是，您无法选择您对产品的评价。假设一位用于减肥奶昔的广告商使用使用产品来促进奶昔的人。对于一个代言人来说，这是不够的，声称他们因失去奶昔而在六个月内减掉了110磅（即使他们有）损失了110磅，除非他们还谈到了他们的饮食变化和增加的运动，这也有助于减肥。

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Expert Endorsement

如果一个影响者表示as being considered to be an expert on a subject, then they actually have to be, i.e. they have to have relevant qualifications and/or experience. While this is clearcut in traditional ads that specify that they are giving an expert opinion, it is a murkier with influencer marketing where the influencers may never claim to be an expert but are simply treated as such by their followers.

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Disclosure of Material Connections

This is the part of the guidelines that has had the most attention of late, particularly in relationship to influencer marketing and social media. They state, “When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement ... such connection must be fully disclosed.”

This is the section which has been flouted by many, if not most, online influencers. It really is very clear. If you are paid in any way to make positive statements online (or indeed in any other way) about a product then you need to let your audience know this. In fact, it doesn't just have to be positive statements. If a firm paid you to make negative comments about their competitors (even if what you said was true) you are still required to disclose this fact.

Of course, in some cases, the average person would expect money to have changed hands, and in this case, no disclosure is required. This is particularly relevant with celebrities. The guidelines give an example of a film star who endorses a particular food product. As referred to above, they are required to give their true view on the product - a known vegetarian should definitely not be giving favorable comments on a meat product, for instance. But assuming that the endorsement is honest, there would not actually be a requirement for the payment to be disclosed, because the average person would expect that the celebrity was being paid.

但是，该指南给出了另一个例子，说明了一个网球运动员在社交媒体上谈论自己的生活。她写了一篇文章，内容涉及由于矫正眼科手术（提供手术的细节以及在哪里完成），她现在如何看待球更好。在这种情况下，由于她使用社交媒体谈论她一生的事件，因此没有理由让普通消费者期望她被付给她提及眼科手术公司。这次，应披露与企业的关系。

另一个FTC示例可能是影响者广告的相当典型的代表。假设一个大学生因其视频游戏技巧而赢得声誉，并维护他的漏洞利用博客（他们可能应该更新此示例以关注YouTube频道）。如果视频游戏制造商给游戏博客作者提供了一些免费游戏，他给了他们积极的评论而没有透露礼物，那么当他们的读者选择购买哪种游戏时，他的读者可能会错误地依靠他的评论。他获得了自由游戏的事实影响了他的评论的信誉，他应该透露礼物。

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那么，影响者营销人员应该做什么？

In simple terms, if you receive money to write a post, status, tweet, share an image, share a video, or virtually anything else online where you are promoting a good or service, you should make it very clear to your followers. There are many ways you can do this, but it must be clear and unambiguous. You can’t hide it behind a More link, as many people used to do on Instagram, and you can’t assume that people know what a #sp hashtag means. Instagram’s “Paid Partnership with…” sub-header is a good move in the right direction.

As福布斯在他们的文章中描述about April’s FTC letter-writing campaign, “The FTC says celebrity social media ads are still too sneaky”. The FTC are leveling the playing field, ensuring that consumers know when influencers truly believe what they are saying compared to when they are just saying it for the money.