A topic we regularly discuss on the Live Stream Insiders weekly show is the issue of live video platforms being a place that increasingly brands and businesses are collaborating with celebrities and social media influencers to help them attract an audience.
Social Media Disclosures On Twitter And Periscope Live Streams
The most recent example we spoke about on the show on the 4 September 2016 is as a result of the announcement that Twitter made that they were introducing a new way for brands to join and add to the Twitter conversation using live video broadcasts and highlights from Periscope using the Amplify programme which I reference in this article.
For this year’s US Open, Andy Roddick has teamed up with brand s Chase and Grey Goose to create a series of broadcasts that will add compelling, relevant live video to the existing #USOpen conversation on Twitter.
You can see some of the streams he has been publishing to Periscope in the image below. The live streams, despite the lack of quality production in relation to lighting and audio, did receive good viewership probably because of the celebrity status of Roddick – but they were also featured by Periscope in the app which would boost views.
Unfortunately however Periscope and Roddick both failed to disclose in most of the live streams that they were sponsored – though one did get a flag to say it was promoted as you can see in the image below. This did raise a red flag to some people posting on Twitter.
If I were the marketing manager for Grey Goose (for context I was an SVP in a number of markets for a FTSE 100 global alcoholic beverage company), I would also be less than impressed with the product placement and association with the series of live streams. I would have anticipated that there would be some recommendations given to Roddick about what they would expect for their investment in the sponsorship.
In one live stream there is a bottle of the vodka placed in the screen – I did not see Roddick consume the product but I would have anticipated that for advertising of an alcoholic beverage there would have had to be some reference to responsible drinking – for example in the UK and Ireland there are codes of practice under the Drink Aware scheme.
Watching that live stream in the app or desk top though you can see Roddick made an error also placing another brand prominently on screen at the beginning of the live stream for Grey Goose – this reminded me of a blogger outreach event almost 10 years ago when the advertising agency managing the event promoting a new advertising campaign for Budweiser in Ireland failed to notice that the brand of alcohol the celebrity film maker was holding was a competitor to Budweiser!
Now let us take a look at what was being posted to promote the live streams on Twitter by Roddick and you will see there is no disclosure such as adding #ad or #sponsored in the Tweets – just the #MasterTheOpen hashtag – this contravenes the FTC guidelines and you can read some of the recent cases in this article on social media disclosures.
I have to wonder who is giving Roddick advice in terms of this campaign – it would not surprise me if the FTC did not investigate the lack of compliance of their guidelines given the prominence of the campaign.
Social Media Disclosures And Complying With Platform Guidelines On Facebook
This week we saw a new set of guidelines come into enforcement on Facebook. This may have escaped your attention, but back in April, Facebook announced an update to their branded content guidelines. Read about Facebook Branded Content here.
On Facebook, branded content includes text, photos, videos, Instant Articles, links, 360 videos and Live videos from Page owners that have verified pages and where that content features third party products, brands, or sponsors.
This change enables publishers and influencers with verified Pages can collaborate with marketers to share branded content on Facebook through ads or organic posts. They also announced they were launching a new tool that makes collaboration on branded content easy and gives marketers more visibility into and control over all their efforts on Facebook.
The tool new tool enables publishers and influencers to tag a marketer (brand or organisation) in a branded content post. The marketer will be notified of the post and can access high-level post insights, including engagement and reach metrics, along with total spend and CPM on the tagged post which is going to be helpful when measuring the effectiveness of influencer marketing. Marketers also have the option of sharing and boosting the post to drive additional value.
While this policy may only apply to verified pages I anticipate that will apply in the future to all pages in the future – after all the FTC requires disclosure in the US and similar situations are in place around the world.
As an example of the new tagging feature for teh Facebook Branded Content guidelines, you can see in the screen shot from a live video post by Mari Smith who has a verified page on Facebook, that the influencer will be asked who is sponsoring the post.
They will get a reminder to tag the sponsoring brand page.
If you are working with social media influencers and especially those with verified pages you need to ensure you familiarise yourself with the Facebook Branded Content Policy – they have some very specific requirements including for example the fact that graphic overlays, watermarks and logos within branded content videos are permitted, as long as they do not appear in the first three seconds of the video. This is a helpful summary of the guidelines.
You can access the extensive PDF of the Facebook branded content guidelines here.
Facebook has stated that branded content will go through a review process and they will be enforcing the usage of the tagging functionality, along with compliance with updated Pages terms and ads policy, for all branded content posts.
Facebook will remove any branded content in violation of, or disapprove ads for lack of compliance with, the branded content policies.
Unfortunately influencers are being found in breach of these guidelines already.
Take for example a series of give aways for a brand in the US which starts this week – the brand (who I personally like – I use their products and have even been provided samples to demonstrate in my workshops) is working with a number of people who will host Facebook Live streams and give always through their pwn pages.
I noticed in their promotions that they were also breaching the rules of the Facebook Page Guidelines where they have stated that entry for people into the give away competitions requires them to like and share the post on Facebook pages of the participating influencers. The Facebook promotion guidelines have been in place for many years.
Two of the participating influencers have verified pages, and one is a Facebook marketing expert so I am surprised that they did not advise the brand of the guidelines.
I have personally advised the brand of the issues relating to the promotion and their non compliance to the two Facebook policies, but at this time they have decided not to change the approach as they comment they were only made aware of the guidelines after they had created the graphics for the campaign.
You can see the Facebook Page Guidelines here – there are a number of things to pay attention to but specifically for the mechanism of entry into the give away see point E3. where they state:
Promotions may be administered on Pages or within apps on Facebook. Personal Timelines and friend connections must not be used to administer promotions (e.g. “share on your Timeline to enter” or “share on your friend’s Timeline to get additional entries” and “tag your friends in this post to enter” are not permitted).
The Facebook Branded Content Policy states that:
Promotions, such as sweepstakes or giveaways, must be tagged appropriately using the Branded Content tool and must comply with section III. E. of the Facebook Pages Terms.
But unfortunately this is not happening at the moment so the verified influencers risk the chance that the post will be deleted for breaching the Branded Content Guidelines and that will potentially become an issue relating to their online reputation – see an example of a post that one of the influencers made about the competition which does not show the tagging as required by Facebook. And all participants – the brands and influencers – risk their pages being deleted for breaching Facebook Page Guidelines for non compliance with the policy for give aways.
As an example this is what the tagging should look like for branded content on Facebook.
In the example from one of the verified social influencers, you can see there is no tagging on this post which means that it is not compliant with the Facebook branded content policy and risk the article being taken down by Facebook as it was posted after the 1 September 2016 when the new policy came into force.
What Can We Learn From These Examples Of Non Compliance With Social Media Disclosures?
In both the Twitter and the Facebook examples of these sponsored events and promotions, it is essential that the team managing the campaign are aware of the policy guidelines for the platforms they are using for the promotions and comply with them
Let us hope that none of the brands referenced in this article are penalised by the FTC or the platforms themselves as this could impact their reputation. I know that I will not share competitions that are in breach of Facebook terms so non compliance could also stop others sharing the campaign.
And if you are a social media influencer you need to be aware of the guidelines from the platforms you use – you can then ensure you inform the brands and businesses that you work with and i am sure they will appreciate you helping them comply with the guidelines.
If you have questions about how to manage a social influencer campaign you can schedule a private consultation with me here.