Yesterday, I had the honor of representing PRSA in a special panel, hosted by the Word of Mouth Marketing Association (WOMMA), examining the impact of the Federal Trade Commission’s planned revisions to its “Dot Com Disclosure” guidelines. I say “honor” because the panel was co-hosted by Rich Cleland, assistant director of the FTC’s Division of Advertising and the Commission’s resident expert on online marketing practices.
PRSA was invited to provide further explanation of our recent commentary to the FTC because we have taken a lead in the public relations industry to advocate for transparent and responsible online communications between brands and consumers. In August, PRSA submitted comments to the FTC in which we advocated for greater clarity concerning online marketing and communications disclosure guidelines. We also requested an opportunity for PRSA and other industry associations and consumer-interest groups to have a voice in the ongoing process to modernize the Government’s digital disclosure guidelines.
Joining me on the panel was Joe Chernov, vice president of content marketing at Eloqoa, who provided insightful commentary on how businesses are potentially using disingenuous SEO techniques to usurp FTC disclosure guidelines.
As I noted at the outset of the WOMMA panel, PRSA believes that our 32,000 members, along with the 200,000-plus U.S. public relations professionals, are responsible in their online communications and marketing practices. PRSA’s Code of Ethics has served as the public relations industry’s de facto self-regulation platform for more than 60 years. More broadly, our peers help weed out those who do not see eye-to-eye with the majority of public relations professionals who believe in honest, fair and transparent communications.
The FTC’s Rich Cleland explained why the Commission does not intend to require businesses to provide a disclosure in every online marcomms touchpoint with consumers. He noted that given the various challenges of doing so in a Twitter-led marketing environment, one that is increasingly dominated by character limitations and other communications restrictions, the FTC will look for ways to meet marketers’ and consumers’ needs that do not onerously restrict how and when and how a business must disclose in social media.
Mr. Cleland also noted that the FTC plans to take an exhaustive approach in developing its revised Dot Com Disclosure guidelines, with updates likely to come early next year.
A full overview of PRSA’s commentary for the WOMMA panel can be found in this PowerPoint presentation (courtesy of WOMMA), which is also embedded below. A quick snapshot:
- PRSA, its members and the public relations industry are committed to responsible and transparent marketing and communications practices — both offline and online. The PRSA Code of Ethics has provided an industry-wide guidepost for ethical and transparent communications for more than 60 years.
- Disclosure is paramount. Online marketers and communicators must make a commitment toward disclosure of relationships, motivation, compensation and other pertinent factors.
- PRSA is committed to enhancing transparency in online marcomms.
- Further restrictions of online marcomms risk stifling innovation. Self-regulation in this space can work, and more timely and clear guidance is needed from the FTC.
- Character and text limitations present new challenges for brand marketers and public relations professionals. There is a growing issue over inclusion of brand disclosures at every point of social media communications and marketing.
- Clarity is needed regarding how brands can reasonably provide disclosures within character-limited social networks. What happens if a consumer modifies a brand disclosure (e.g., through an “MT,” or modified Tweet in Twitter)? Where does the responsibility lie to ensure FTC compliance once the brand disclosure is presented online to a consumer?