As a next step in the process, WOMMA is working to finalize the explicit best practices for social media disclosure for both marketers and bloggers* (like the FTC, WOMMA applies the term “bloggers” to refer to individual posting online content, whatever the channel).   Comments will be accepted until January 5 and final guidelines will be submitted shortly thereafter.

Our goals:  Facilitate dialog around and provide explicit recommendations around:

• Where and how marketers can effectively and transparently disclose — and be in compliance with FTC Guidelines
• Where and how “bloggers” can effectively and transparently disclose — and be in compliance with FTC Guidelines

WOMMA has been following a very deliberate process to gain membership and industry consensus on these issues

• Began dialog at 2008 WOMMA Summit
• Convened expert panel on transparency and disclosure
• Facilitated discussion on “Living Ethics” blog
• Drafted preliminary disclosure guidelines
• Reviewed preliminary disclosure guidelines at 2009 WOMMA Summit (November 20)

Our next steps are to post current guidelines here on the Living Ethics blog for feedback and then to issue final recommendations.

Please review all of the following information and provide any specific suggestions on what would make the direction either clearer or most consistent.

Key platforms we’re covering:

• Blogs/forums
• Video and photo sharing sites
• Social Networks
• Review Sites
• Twitter
• Other forms of user generated content

Our Guiding Principles:

• Disclosure must be clear and conspicuous
• Language must be unambiguous
  • Considerations must be given to targeted consumer
• Disclosure must appear “above the fold”

Marketers’ responsibilities:

• Educate “bloggers” regarding responsibilities
• Educate internal corporate audiences regarding responsibilities: create a “culture of compliance”
• Require disclosure from “bloggers”
• Monitor to ensure disclosure is happening

“Blogger” Responsibilities

• Confirm understanding of responsibilities with marketers
• Disclose all material connections
• Communicate proactively with marketer to demonstrate compliance

Best practices for: Blog Disclosure:

• Editorial blog
  • Disclose any product, service or compensation provided by a marketer
  • Disclosure requirement:
    • As part of editorial copy
      • “I received ____ from (company X) as a sample, to review, etc.”
• Review blog
  • Disclose any product, service or compensation provided by a marketer
  • Disclosure requirements:
    • As part of editorial copy
      • “I received (X product or service) from (company X) to review”
      • “I was paid by (company X) to review”
  • Create “Disclosure and Relationships” section on web site

Best practices for: Video Sharing Sites

• Video sharing sites
  • Disclosure options:
    • As part of video content
      • “I received (X product or service) from (company X) to review/create this video
      • “I was paid by (company X) to review/create this video”
      • As part of video description

Best practices for: Photo Sharing Sites

• Photo sharing sites
  • Disclosure requirement:
    • As part of photo description
      • “I received (X product or service) from (company X) to create this
      • “I was paid by (company X) to create this”

Best practices for: Social Networks

• Social networks:
  • Disclosure options:
    • As part of photo or video description (see photo and video sharing sites best practices)
    • As part of status update
      • “I received (X product or service from (company X)
      • “I was paid by (company X)
  • Create “Disclosures and Relationships” section on profile

Best practices for: Review Sites

• Review sites:
  • Disclose any product, service or compensation provided by a marketer
  • Disclosure requirements:
    • As part of editorial copy
      • “I received (X product or service) from (company X) to review”
      • I was paid by (company X) to review”
  • Create “Disclosure and Relationship” section on profile of website

Best practices for: Twitter

• Twitter
  • Disclosure requirement:
    • Must clearly state hash tag within tweet
      • #spon or #paid
  • Create link to “Disclosures and Relationships” section on profile

The importance of the WOMMA Ethics Code and the Living Ethics Project is most notable in the recent announcement of the FTC Guide changes.  The FTC referenced and adopted WOMMA’s guidance in several instances, looking favorably upon the Association’s own Ethics Code, and adopting WOMMA’s suggestion that only “sponsored” communications should fall within the scope of the Guides.  Therefore, adherence to the WOMMA Ethics Code is a critical first step for businesses and marketers in complying with the updated FTC Guides.

Several fundamental principles of WOMMA’s Ethics Code, such as the importance of transparency, disclosure and honesty across all media, are now required by the FTC.  WOMMA believes the updated Guides will usher in a new generation word of mouth of viral and social media marketers who place the highest priority on ethical practices.  WOMMA President Elect Paul Rand explained, “The greatest value we can provide to our 300-plus members is helping them navigate the uncharted waters of social marketing.  WOMMA takes great pride in not only equipping members with a venerable compliance ‘how-to,’ but also in the collaborative way we went about influencing policy, itself.”

Members input and guidance is extremely important to ensuring that WOMMA and our Ethics Code continues to be at the forefront of the industry.  Members are asked to go to the Living Ethics Blog from November 16 – January 5, 2010 to submit comments, questions or concerns.

The Board of Directors of WOMMA will take into consideration all comments submitted as well as general research and trends and determine if changes need to be made to the WOMMA Ethics Code. The result of this will be publicly announced to the WOMMA membership via the web site and direct email.

Should you have questions about the Living Ethics Project, give us at a call at 312-853-4400 or email us at membership@womma.org.

Best regards,

Kristen L. Smith, CAE
Executive Director, WOMMA

Sincerely,
Kristen L. Smith, CAE
Executive Director
WOMMA
Kristen@WOMMA.org
Twitter: @KristenWOMMA

*****************************************************************************

At the conclusion of this time period, WOMMA will produce minimum guidelines for the industry as to appropriate practices. The key points from our panelists this call included:

·  Three areas are needed for effective disclosure:
(1) being complete (explain what was provided by a brand);
(2) be in context (explain clearly the relationship between yourself and the brand);
(3) being yourself (confirm what you say is truly your opinion).

·  Bottom line from a legal perspective, disclosure must be clear and conspicuous.

·  Sites badges are proving to be effective in disclosing material relationships.

·  Marketers/brands should monitor and be responsible for what is being said by the bloggers they are working with.

·  In its current state, Twitter is not conducive to disclosure. Not enough space to do it adequately and effectively.

*****************************************************************************

Please join the conversation and post your comments here as well as pass this link along to encourage others to submit their thoughts.  The more people, businesses, etc. that we have involved in this conversation the more robust and positive our outcome will be for the industry.  Be part of the solution – participate, advocate and get involved.

As many of you are aware, one section of the WOMMA Code of Ethics was re-opened after the requisite three members requested a review. More than 60 members and interested parties commented on whether the statement, “We stand against marketing practices whereby the consumer is paid cash by the manufacturer, supplier or one of their representatives to make recommendations, reviews or endorsements” should be part of the Code.

After much deliberation, there is 100% agreement among the MEAP (Member Ethics Advisory Panel) and the WOMMA Board of Directors to refine this section of the Code of Ethics. The aforementioned statement will be replaced with the following:

We stand against marketing practices whereby the marketer or its representatives provide goods, services or compensation to the consumer to make recommendations, reviews or endorsements without full, meaningful, and prominent disclosure.

A final version of the Code can be found at (http://womma.org/ethics/code/).

While few would disagree with the need for disclosure, there is an increasing industry demand to qualify and provide direction on what constitutes “full, meaningful and prominent” disclosure. If, for example, a consumer is given a product to review he/she must clearly state that in their review. If someone is paid to write a review, that too must be fully, meaningfully, and prominently disclosed.

As part of WOMMA’s ongoing Living Ethics program, we be will launching a “straw man” outline regarding disclosure and asking our members and community to provide input. We will also be conducting a live “disclosure debate” to bring together some of the leading thinkers in the space to help shape what can become an industry-agreed standard regarding the right and best ways to disclose.

The new disclosure guidelines will be formally unveiled at the WOMMA Summit, being held November 18-20 in Las Vegas.

Thank you to all who have participated in this important process. Please post comments/questions here.

Best regards,

As many of you are aware, we are re-evaluating an element of the WOMMA Ethics code as part of the Living Ethics program.   The Code was re-opened after the requisite three members requested a review.  More than 60 members and interested parties commented on whether the statement, “We stand against marketing practices whereby the consumer is paid cash by the manufacturer, supplier or one of their representatives to make recommendations, reviews or endorsements” should be part of the Code.  The Board of Directors met and has held extensive conversations and conducted research around this specific issue in order to render a decision back to our membership by July 31st.

We’re not quite there yet.  So, please stay tuned.  We’ll likely have final feedback before the end of August.  In the interim, this issue will continue to be held in abeyance.

In the meantime, WOMMA will be launching an industry discussion around meaningful and effective disclosure in anticipation of what WOMMA expects will be in line with the soon to be released FTC Guidelines.   Look for further information on this initiative later in August.  We hope everyone WOMMA member will be actively and aggressively involved.

If there are any questions or concerns, please do not hesitate to contact me or Kristen Smith, WOMMA Executive Director, at Kristen@WOMMA.org or at 312-853-4400.

Sincerely,
Paul Rand,
President-Elect of WOMMA
CEO Zocalo Group

As you may recall, one section of the WOMMA Code of Ethics was re-opened after the requisite three members requested a review. To date, more than 60 members and interested parties have commented on whether the statement, “We stand against marketing practices whereby the consumer is paid cash by the manufacturer, supplier or one of their representatives to make recommendations, reviews or endorsements” should be part of the Code.

Under the outlined procedures, the WOMMA Member Ethics Advisory Panel (MEAP) and I will review the feedback and make a formal recommendation to the Board of Directors, which will be announced by July 31, 2009.

Once the Board has reached a decision the following will happen:

• WOMMA will confirm to all members if a change that has been made.
• WOMMA will provide members a 180-day compliance period in which to comply, if necessary, with the new Ethics Code.
• If member companies are unable to comply with the changes the Ethics Code, any affected member company will be asked to resign from WOMMA membership.
  
  

The Living Ethics Project is an annual review of the Ethics Code. WOMMA is striving to ensure that we respond effectively to you, our members. It is imperative to the strength and growth of our industry that we remain proactive in our approach to ethical and effective word of mouth and social media marketing.

Should you have any questions, please do not hesitate to contact Kristen Smith, Executive Director at WOMMA at Kristen@WOMMA.org or me at prand@zocalogroup.com.

Regards,

Paul M. Rand
WOMMA President-Elect
President/CEO, Zócalo Group

Please continue to weigh in on the main question, but would also like feedback as to whether receiving cash needs to be disclosed differently than receiving product.  Is one form being paid for a job and the other simply being asked for an informed opinion?

Three WOMMA members, as part of the Living Ethics Review process, have formally asked that this issue be revisited.  Through this blog, we are hoping to generate comments from WOMMA members, industry insiders, bloggers and brands.  At the end of June, the WOMMA Board will consider whether to revise the Code, as currently written, or to leave it as it now stands until this Fall, when the formal review period commences.

Paid Blogging:  Ethical or Not

Forrester’s Josh Berhnoff, is an AdAge Article, stated that paying bloggers for recommendations is “easily the most contentious issue I’ve dealt with recently.”  He’s right.  It’s driving strong points of view on all sides.

So, please make your opinion heard.  Is it ethical or even acceptable for brands to pay bloggers cash to write reviews?

The Living Ethics Blog is now available to discuss/debate the following issue:

“We stand against marketing practices whereby the consumer is paid cash by the manufacturer, supplier or one of their representatives to make recommendations, reviews or endorsements.”

This item in our Ethics Code was brought forward by three members in good standing to open dialogue as part of the WOMMA Ethics Code Interim Review Process.   The Blog will be live from June 1 to June 30th.    WOMMA strongly encourages members, interested parties, and consumers to submit comments on this issue. This issue will be held in abeyance for a period of sixty days. All of this information will be publicly stated on our web site so the entire process will be clear and transparent. In addition, after the comment period has ended, the Board will take all communication/discussion on the topic and render a final and binding decision.

]]> http://womma.org/ethicsreview/2009/05/31/open-for-comment/feed/ 3 http://womma.org/ethicsreview/2009/01/22/are-hoax-posts-and-videos-ethical/ http://womma.org/ethicsreview/2009/01/22/are-hoax-posts-and-videos-ethical/#comments Thu, 22 Jan 2009 22:16:01 +0000 Paul Rand http://womma.org/ethicsreview/?p=88 As marketers, is it ethical to have fun and be “playful” with social media if our efforts are designed to be a “hoax”? 

Current example making rounds is a video involving a menswear company.

Thoughts?

————————————————————————

Is it ethical to target WOM marketing to minors?

Is it ok to pay bloggers to write about your or your client’s brand?

Is it ethical to create and maintain multiple online identities when engaging in digital word of mouth marketing?

These and other questions are at the heart of WOMMA’s Living Ethics project and revisions/update to the WOMMA Ethics Code – regarded as the industry’s standard.

We held a live ethics session during the WOMMA Marketing Summit in Las Vegas and many people participated. If you’d still like to watch the session, go to http://womma.org and click the link for the Live Ethics Video on the homepage.

Since getting back to Chicago, we’ve hosted a blog for members and the public to discuss ethical issues in word of mouth marketing and any refinements needed to the Ethics Code.

Please go to http://womma.org/ethicsreview to make your voice heard in this important discussion. We’ve extended the deadline for comments until January 20, 2009. Revisions to the code will be announced in February 2009.

Should you have questions about the Living Ethics Project, call WOMMA staff at 312-853-4400 or contact me directly at 312.596.6272 or at prand@zocalogroup.com.

Have a wonderful holiday!
Paul M. Rand 

VP, WOMMA Board of Directors
Chair, WOMMA Living Ethics Project
President/CEO – Zócalo Group

The current WOMMA ethics code re minors is outlined below.  Does this go far enough?  Too far?  Changes needed?

We manage relationships with minors responsibly

• We believe that working with minors in word of mouth marketing programs carries important ethical obligations, responsibility, and sensitivity.
• We stand against the inclusion of children under the age of 13 in any word of mouth marketing program.
• We comply with all applicable laws dealing with minors and marketing, including COPPA and regulations regarding age restrictions for particular products.
• We ensure that all of our campaigns comply with existing media-specific rules regarding children, such as day-part restrictions.

While WOMMA is not a “policing” organization, we do have a process in place to investigate possible breaches of the code.  When a WOMMA member formally presents a complaint about a possible Code violation (which has occurred in this case), the issues is turned over to our Member Ethics Advisory Panel (MEAP). The Panel will now review the case to determine if there has been a violation.  The group will return with one of three outcomes: There has been a violation and the member must address the violation or risk losing membership; 2., There has been no violation 3, There has not been a formal violation of the Code, but there has been a violation of the “spirit” of the Code and the member receives a warning.

. Our ultimate goal is to protect our members, our brands and the consumers — while at the same time continuing to refine and reinforce the WOMMA Ethics Guidelines as the Industry Standard that provides clear direction to all marketers.

This is at the heart of what the current WOMMA Living Ethics project is all about.  Our industry is changing.  Please make sure to make your comments and voice heard.

So … is this an ethics violation?

One of the most lively debated topics was:

* Should people be paid to review or comment on blogs? If they are paid, is that okay as long as it’s disclosed? (defining payment as cash, not incentives)

Any thoughts here?

We’ll explore the other most relevant word of mouth marketing, disclosure and ethics issues in days to come.

Paul M. Rand, VP of WOMMA, President/CEO of Zocalo Group.