This week, PRSA submitted formal comments to the Federal Trade Commission concerning potential revisions to the Commission’s “Dot Com Disclosures: Information About Online Advertising.” This document laid the groundwork for how businesses communicate with and advertise to consumers online.
It’s not an exaggeration to say that this seminal guide dramatically enhanced the level of transparency in online marketing and communications between businesses and consumers.
But like all good things, updates are necessary. The proliferation of new technology and social networks have given businesses many exciting opportunities to reach and market consumers online. Yet, issues have arisen regarding online consumer protections. When the original guidelines were issued in 2000, Twitter and Facebook didn’t exist and most online advertising occurred through banner or display ads. The ability to track, engage and market consumers within these mediums was relatively immature.
Clearly, dramatic changes have taken place in the last 11 years.
With that in mind, PRSA seeks more clear guidance and examples from the FTC regarding how online disclosures should be implemented, given the new challenges and realities marketers face daily. We strongly believe that our 32,000 members and the broader public relations profession are committed to transparent and ethical communications and marketing practices that serve the public’s best interest and protect consumers.
Furthermore, we urge the FTC to avoid implementing stringent regulations of Internet marketing that could dull innovation and hinder growth of digital communications channels that consumers have expressed great interest in using.
Overview of PRSA’s comments to the FTC:
- Disclosure of relationships, motivation, compensation and other pertinent factors should be the basis of all forms of marketing and communications, including emerging practices like social media and online contests.
- Clarity of brand disclosures is paramount. Companies should be transparent in their communications and marketing. Businesses should aid in the decision-making process for consumers, rather than adding to the confusion that can accompany online purchasing decisions.
- The proliferation of character and text limitations by social networks requires the FTC to examine whether the inclusion of brand disclosures is necessary or practical at every point of social media communications and marketing. Clarity is needed from the FTC regarding how brands can reasonably provide disclosures within character-limited social networks.
- The FTC Guides on the Use of Endorsements and Testimonials contain parallel regulations and guidance concerning online marketing and communications and should be incorporated, in whole or in parts, within the FTC’s revised “Dot Com Disclosures” guidelines.
- The FTC should hold a public workshop on these issues to obtain the full input from all stakeholders.
PRSA has a long history of proactively leading the public relations profession in communicating its role and values to federal regulators. Last December, we filed commentary with the FTC concerning transparency in environmental marketing communications.
You can view our full commentary to the FTC below. And please offer your comments on the guidance you’d like to see from the FTC’s new online advertising disclosure guidelines.