Implementing a Social Media Policy
The hot topic of the PMA Law Conference this year was social media. It was a hot topic indeed, in light of the recently published FTC Guidelines concerning the use of testimonials and endorsements in advertising and social media, as well as the new Facebook policies put in place the day before the conference. Naturally, many questions arose throughout the conference discussions. One overarching concern for marketers about this topic is “How do we protect ourselves and our clients in this ever-changing environment without inhibiting the creative use of these social media marketing tools?”
The take away is basically this: create a social media policy for your company.
HOW DO I KNOW IF MY COMPANY NEEDS A SOCIAL MEDIA POLICY?
Is your company or brand leveraging social media in their marketing strategy? Has your company created a fan page on Facebook or established a company account on Twitter? Maybe your employees are tweeting about the company on their personal accounts. If so, then it’s time to consider creating a social media policy, a tool to help your employees navigate the social media jungle.
WHAT IS A SOCIAL MEDIA POLICY?
Like any good set of terms and conditions or Official Rules, a social media policy will outline what information should or shouldn’t be posted to any social media platform in order to avoid violating the FTC Guidelines. It should apply to any employee, agency or blogger who posts information (that can be attributed to your company or product) to any social media site; including their own or the company’s blog, Facebook fan page, or Twitter account.
In short, the new FTC Guidelines cover all advertising messages including product reviews, endorsements and testimonials, hosted on blogs and social media sites like Facebook and Twitter. Compliance with the FTC Guidelines is all about disclosure. So, bloggers, and in some cases your employees (or agencies, or even your mom, if she likes to brag!), who make these “endorsements” must disclose the material connections they share with the Sponsor. This way, consumers are aware when the author of a review/testimonial has been paid or received free product in return. Your social media policy would outline how your employees, agents and bloggers should conduct themselves when talking about your brand and products on the web.
WHAT SHOULD A SOCIAL MEDIA POLICY DO?
- Provide guidance and training to those people who are involved in social media for your company.
- Make a reasonable effort to monitor your company’s social media platforms including blogs.
- Make sure you have reserved the right to remove false statements when identified or anything that is posted that you think could be problematic.
- Train all people involved in social media for the need to be truthful. Stress the need to provide honest & truthful opinions to avoid false advertising claims.
- Instruct your people to disclose the connection to your company (whether they are employees or bloggers provided with free product).
- Instruct your people to respect all Intellectual Property rights.
- Explain that all statements made must be verifiable.
- Require sponsor approval if bloggers wish to run a contest.
- Limit employee social media direct messages (may be considered email and fall within CANSPAM).
Make sure the social media policy is reviewed by marketing, HR, legal, PR departments and your advertising agency so you have everyone’s input.
WHY A SOCIAL MEDIA POLICY?
While not fool-proof, a social media policy will help steer those in your company to walk the right path when it comes to sponsored messages and testimonials on social media, and having one in place may determine whether or not an action will be brought against your company, should an infraction of the FTC Guidelines occur.
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