The Word of Mouth Marketing Association (WOMMA) and the FTC agree: material relationships should be disclosed when posting comments, tweets, status updates and the like. I understand this may not be news to many. However, I still see many people overlooking disclosure when it comes to posting negative comments or spreading negative news about competitors — especially on Twitter.
So much has been discussed about ethical disclosure in promotion in the last year since the updated FTC guidelines were announced, but we haven’t heard nearly the amount of noise over competitor demotion even though the rule certainly governs each.
The Social Media Group published an overview for companies on compliance with the FTC guidelines:
- Disclose whenever you have a relationship with an advertiser, brand or company. This has specific implications for employees. You must make a disclosure if you work for Acme Widgets and you mention your employer, competitors, or the widgets industry in a blog post, tweet or elsewhere online.
- You must also disclose the name of your employer if you are commenting on a forum thread or in a group about Acme Widgets, the widget industry or about a competitor.
This all seems pretty clear to me.
Material Relationships Work Both Ways
If I work for a company and I’m promoting its good news on Twitter, everyone expects me to disclose the fact that company I’m tweeting about is my employer — either in the content of my post, or in my profile information. Makes sense, right?
The reason behind this law is that consumers encountering user generated content need to readily distinguish between bona fide word of mouth buzz from consumers with nothing to gain from sharing positive information about a company or product, and those who are expected to promote the organization out of material self interest.
There’s nothing wrong with sharing positive information about your company. If I work for the company that may change how you feel about the information I share and that is your right as a consumer.
Now, let’s say I run across some negative news about a competitor company and begin posting that news on Twitter. My status as an employee with a direct competitor might also change how you feel about the information I’m spreading online. At least if you knew, you could decide whether or not you should take my participation in distributing this news with a grain of salt, right?
My point is this: You don’t just have a material interest in your employer, but also your competitors. I’m not necessarily proposing additional laws, but negative posts without disclosing a competing interest is just as suspect as astroturfing for your employer or client company.
You Are the Context
Information in social networks has the potential to surface on the Internet out of context. Real-time search, aggregators and Twitter search make it possible for your updates to make traction into other places online you may never visit. Comments on mainstream news sites and blogs also have this potential.
If your material relationships mean you can’t possibly be objective, you should either disclose your relationship, positive or negative, or stick to other subjects.
I get that there can be a lot of gray area associated with disclosure and ethics — how much material is required for a material relationship. What if you used to work for a company, but don’t anymore? However, the law seems to provide a pretty firm foundation for honest engagement — the rest is up to you.
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