Best Practices on Blogger and Compensated Endorsers
Best Practices - Steps to Addressing Compensated Endorsers and Reviewers
- Inventory any formal reviewer practices and inquire about any ad hoc or informal practices where virtual goods or services, or any consideration is given to online influencers, reviewers or bloggers.
- Decide which of these reviewer relationships add value and discontinue the rest.
- Advise the ongoing reviewers about the rules and requisite disclosures, and enter into an agreement with them (or notify them of the terms of sample or perk programs) as a condition to their receiving promotional, free products, services or virtual goods or special access or other consideration.
- Identify all external spokespeople and review any contracts and arrangements with them regarding outreach and public statements for compliance. Create awareness among your promotional teams. Create a firm disclosure policy and include that policy in future contracts and as an addendum in existing contracts. (You may be able to just provide notice of the law, as most contracts include an obligation to adhere to applicable laws.)
- Create Google, Yahoo! and Bing alerts to track references to the company or its products or services, especially by compensated reviewers or online influencers or compensated spokespeople. Appoint someone to track these for compliance.
- Assign an internal owner of this issue within the company and a chain of command and policies for escalation of questions.
- Coordinate the compensated reviewer policy with any fan or celebrity management policies and any consideration or special perks or access to consider compliance issues with fans and celebrities.
- Articulate your compensated reviewer policy on your website and to relevant internal staff and external marketing and PR advisors. And provide a disclosure about spokespeople and related media referral relationships on the site as well.
- Create a disclosure document, couched as a one-pager describing any celebrity spokesperson and your products, to provide to production staff for TV appearances and to include in your media kits. Link back to website disclosure.
- If you are sponsoring or otherwise have a financial interest in studies, polls or surveys conducted by others that have a bearing on you products, services or practices, that sponsorship or interest must be disclosed. Provide a pre-approved disclosure that can be used, and use it as an opportunity to show support for research and why you are involved in the issue.
- Check existing insurance coverage and consider adding on interested party/blogger compliance coverage. It may fall within general legal risks, and not be broken out as long as you have something in writing referencing compliance coverage, especially for the acts of third party bloggers, etc.