The FTC recently clarified brand responsibilities for social media policies, in the form of Three Ms, as follows:
- Mandate a policy that’s in compliance
- Make sure people you work with (or on your behalf) know what is in compliance
- Monitor for compliance (reasonable systems must be in place). The FTC does not seem to accept affiliate agreements alone as evidence that companies are policing their affiliates.
When the FTC says Monitor, they mean that you should audit and spot check your processes. They are not suggesting that you use a social media monitoring tool to track every mention of your brand or campaigns.