As the FTC increases its enforcement of its Guides, social media policies are getting a lot of attention, marketing attention from law firms, and blogs that offer bad or incomplete advice. Here are a couple of mistakes I’ve seen in recent blogs about social media policies:
Stating “This is my personal blog. All views expressed here are solely mine and not those of my current or past employers.” — which is stating that the opinions you express are your own — is the opposite of disclosure. An example of disclosure would be writing an opinion about a magazine’s publisher, and then disclosing to readers that you get paid to write for the magazine.
The FTC requires that brands and their agencies maintain and train their people on social media policies that ensure compliance with FTC guides. As a brand, your policy responsibilities extend to your agencies, so make sure they are meeting their obligations.
In fact, the FTC recently published guidance a framework for brands to ensure they are doing the right things, which I describe in this post.