Digital Influence Mapping Project

Join Us for a Post-FDA Tweetup in DC

WOMMA and Ogilvy will be presenting at the FDA "Social Media" hearings this week in Washington DC. I will be speaking on behalf of WOMMA in my role as President of the Board. Rohit Bhargava will be presenting on behalf of Ogilvy in his role spearheading our Digital Health business. We have all been waiting for some time for the FDA to engage and start evolving their guidlines to address the changes wrought by social media. The 2-day hearings is just a start. And a ton of experts will speak over those two days.

On Thursday night, November 12th,  from 6:30pm - 8:30pm, WOMMA and member companies -  Live World and Ogilvy PR -  will have a tweet up at the Ogilvy offices in DC (1111 19th Street - 10th floor). Tony DiResta who is WOMMA's legal counsle will give a post-hearing wrap-up and a lot of us who participated will be there offering our won thoughts. Mostly its social.

You can RSVP here or just show up.

WOMMA to Present at FDA Hearings on Social Media

On Friday, November 12th, Melissa Davies, Research Director at Nielsen, and I will present on behalf of WOMMA during two sessions with the FDA. These are part of the long-awaited FDA foray into considering new guardrails for health products marketers in social media. Pharma, one of a few heavily regulated industries, has stepped cautiously into social media over the past few years. Still, pharam is not as paralyzed as some would suggest. Dose of Digital maintains a great list of pharma social media activities from Twitter to communities.

WOMMA has just gone through a productive year with the FTC that culminated recently with the FTC Guidelines on Endorsements and Testimonials.We will have a follow up session with the FTC at this year's WOMMA Summit in November.

WOMMA's Role

Ultimately, WOMMA wants to protect the consumer and the trust that brands can build with consumers if they use social media well. Consumers increasingly expect brands to engage and be available in social media. Brands value third party word of mouth as one of the most trusted sources for opinion and purchase decision. Brands and consumers want to connect in socila media. And we have to do it right or the basic premise beneath WOM - trust - will crumble. We also want to empower marketers to productively engage within social media. Pharma has been held back in part because of their fear of additional regulations or actions.  

The FDA's 5 Questions

The FDA has set up a listening session on November 18 and 19. The agenda is full of marketers and each of us has a 10-minute slot to help inform the FDA's 5 questions. 

It is not clear yet if these are even the right 5 questions. Still, in respect to the FDA and the simple principle that we have to start somewhere, I am grateful that they opened their doors. You can review the FDA's Notice of Public Hearing here.

Here are the 3 questions we plan to address with a quick summary of our POV:

Question #1: For what online communications are manufacturers, packers, or distributors accountable?

In today’s social Web marketers and consumers alike are flocking to third party sites and platforms both to be where consumers are and to garner legitimate third-party mentions that corroborate their products’ benefits or around a topic related to a disease or condition. The power of word of mouth means that marketers want influencers/bloggers to experience their topic, product, or service that relates to a brand and then share about it authentically.

WOMMA has an aggressive POV on what is proper disclosure both in spirit and actuality. Aligned with the recent FTC Guidelines, we see the opportunity for marketers to not only practice ‘full disclosure’ of any and all material connection between brand and influencer/blogger, but also to strongly encourage those influencers to do their part to properly disclose. As with the FTC Guidelines, it doesn't take payment to define a material connection. Marketers are better off disclosing any type of material connection whether they be travel expenses for a health blogger, technology support on an unbranded community, or even the snacks at a tweetup. Disclose and let the consumer judge credibility. 

Question #3: What parameters should apply to the posting of corrective information on Web sites controlled by third parties?

Social media is defined by conversations and a hyper-democratized  approach to publishing. Brands and marketers want to connect more directly with customers to better understand their needs and build a stronger relationship. In addition, brands want to ensure that the full story behind products are shared outside their Web sites. They want to be where consumers are spending their time and that is increasringly across the social web.Can pharma marketers be allowed the opportunity to comment on blogs and message boards – completely transparent about their identity and interests – to help keep the information about medical products as clear as possible?  Most pharma marketers do not feel empowered to comment or "fact correct" as the historic FDA guidelines might interpret that as a new instance requiring advertiisng or labeling information. Imagine if every comment required that full page disclaimer you see in print ads.  Conversely, we must not require an unsupportable burden - the requirement to "story-correct" across the vastness of social media. Like the FTC Guidelines, the marketer must focus their energy on keeping their own communications accurate and encouraging and even enforcing accuracy from any influencers they proactively outreach to.

The challenge with health care information is to allow for this conversational interaction while always putting the full story behind products and services front and center. No blog comment field or Tweet will sustain the full content of a product Web site. We may need to allow pharma a consistent "one-click" solution where marketers can comment and link back to the full body of a product insert.  

Question #5: Specific to Adverse Events Reporting

One of the biggest effects of social media is the new opportunity for brands to hear what consumers are saying in public discussions about products, services and issues important in their lives. Smart marketers have adopted “big ears” to make sure they listen and respond to customer concerns. 

The historic and important requirements around adverse events reporting have held many health care marketers back from listening to consumers. How the intent of adverse events reporting actually applies when a patient posts a product experience in Twitter with no contact information in their “bio” or exactly when an adverse event is established over the course of several blog posts is not clear. We need to find a clearer way of recognizing an adverse event and then reporting it that does not hold back a marketer from listening to what consumers are saying in the public space.

Outcome of the Hearings
The real solution may lie in the FDA establishing clear principles and then encouraging the industry to define exact practices as we are doing at WOMMA in relation to the FTC Guidelines. Can the FDA really hope to define the exact nature of a url or how to balance their historic need to approve marketing claims with the non-stop, real-time nature of a twitter-ized social Web? Will this type of detailed regulation help or hold innovation back? We need principles that protect the consumer but do not curb marketers from innovating.

Stop by:

If you are in DC for the hearings, stop by Ogilvy on Thursday night. WOMMA, LiveWorld and Ogilvy will be hosting a post-hearing Tweetup to recap what we heard that day. RSVP Here

   

The Trends in Next Generation Listening Posts (and Looking Glass)

We have reviewed and worked with many of the leading technology companies curently providing consumer generated media (cgm) monitoring solutions for brands. After having done two enterprise-level evaluations for global brands - each with different geographic focus - it is clear that the market is shifting.

We just went through a deep-dive on Microsoft's Looking Glass which points to a further evolution of the market towards in-house and integrated solutions. Is that defiance of the SaS model or are they accurately anticipating where big brands need to go in the future?  

Before I get to Looking Glass, Here are a few of the trends I am seeing:

1. the early lead of service providers who do everything from the technology to the insights is falling away. In its place are dashboard technology providers that put the tools in the hands of brands and agencies - the folks that know the brand business. Even Nielsen has a simple dashboard solution.

2. technologies are focusing on 1-2 of the 7 major purposes of Listening Posts. They are slowly focusing their strengths in certain areas and being more open about admitting what their solution or organization cannot support

3. there is a whole new set of technology providers who are building a flexible framework to be applied to multiple language markets. Once you broaden your view to identifying technologies that work across 4 or 5 language and geographic markets, you suddenly see a whole new set of providers like eCairn, Attentio, Brandwatch and others popup.

4. automated sentiment rating continues to be a holy grail (solutions with 60% accuracy are near-useless) except amongst a very few who have made progress notably Crimson Hexagon and Collective Intellect.

5. brands are splitting between those that want simple and fast and those that want tailored and highly relevant. Radian6 smartly stepped into the simple and fast space and continues to excel there even as others launch comparable "monitoring-only" solutions. A few brands have buy-in to invest the time and money for more tailored solutions. Which brings us to:

Microsoft's Looking Glass

We recently met with the development team at Microsoft responsible for their monitoring/listening solution dubbed Looking Glass. The solution is a 3 server-based model and sits on top of or integrates with Silverlight for the display layer, SQL server and Sharepoint. It is a work in progress and has some significant advantages over other solutions depending on which of the 7 reasons you need a Listening Post and what other Microsoft investments you have made.   

Here are 4 reasons that Looking Glass may be great for enterprise listening:

1. It uses Bing for blog and Web search. That engine will likely provide a strong heart for teh service for years to come.

2. Its real power is in the customizability down to its ability to pull in new data feeds. That means that enterprise can combine data feeds that are most relevant to them (the future of Social IRM is in the integration with CRM databases. This platform will handle that.

3. The Silverlight-powered display is good-looking. Don't underestimate the power of great information design to make listening solutions usable.

4. Like Visible Tech it features task-delegation functions. If you want to assign someone to respond to a Tweet or a post, you can do that within the system and track those responses.

This is meant for the more advanced enterprise willing to invest the integration and customization hours never mind the hosting/serving of it. As we move towards more advanced models of integrating cgm listening into the enterprise like the Social IRM model, the Looking Glass model may be a strong solution. Everyone awaits the debut of the next Google Labs experiment where they deliver the 30 ton megaton bomb on teh listening market with their own solution. I only presume that is somewhere inside their skunkworks....

Wall-to-Wall Brand Cases, the FTC and Sugarland: WOMMA Summit 2009

This year's Word of Mouth Marketing Association (WOMMA) Summit is something else. It is the fruit of two years effort by a lot of smart marketers to bring the best of social media and word of mouth marketing together. We wanted to help experienced marcom experts share best practices in the best way possible - via our peers. As current Board President of WOMMA, I can proudly say that this event reflects the essential and exciting role WOMMA plays now.

Here are 7 reasons why this year's WOMMA Summit is a must-attend event for any marketer who needs to apply social media in a disciplined, impactful way:

1. The best insight comes from real brand cases. WOMMA Summit will feature disciplined cases from Ford, Tropicana, General Mills, Coca Cola, Pepsi, Microsoft, CDW, IBM, SAP, Walmart, BestBuy, HP and more. Learn from real practices.

2. Our session "The Role of the FTC in Word of Mouth and Social Media Marketing" will feature the Chuck Harwood, Assistant Deputy Director. he will help everyone better understand the new FTC Guidelines and WOMMA's next effort to define best practice disclosure

3. The Brands Council at WOMMA will host its own meetups for brands allowing marketers to share experiences and get advice from their peers.

4. Ray Day, VP of Global Communications at Ford, and Scott Monty will keynote and share insights about how Ford has woven social media into the fabric of the company.

5. A post-hearing analysis session dedicated to the FDA Hearings on social media in health product marketing.

6. A full "track" dedicated to Research and Measurement AND the release of a final draft of the WOMMA Measurement Guidebook. I don't know about you but measurement - both performance and ROI - is the most important issue from brands who want to expand their use of social media. You will get practical, applicable-now models.

7. The first annual WOMMY Awards will identify the best of the best in social media and word of mouth marketing (I think there were over 200 entries!)

Bonus reason: The band, Sugarland, will keynote about their extraordinary work with fans and that's just cool.

This will be a terrific and talked about event. Just go to the Website and judge for yourself. In tough economic times, we each have to choose what is essential to our business. This event was designed to deliver an essential experience for brands and marketers needing to learn expert and best practices for social media from the people actually doing it not just talking about it!

When: November 18-20
Where: The Paris in Las Vegas (a Harrah's property!)
How: Go here to register 
Go here to learn more

Register today with the code "fanofogilvy" and receive $200 off the fee. There will be no other discounts.
I will be there. Tons of brands will be there. I hope to see you there. 

The Power of Owned and Earned Media

The power of social media going forward is in integrated programs, not stand-alone, "earned" media programs. It doesn't take a rocket scientist to understand that complimentary media - social (the new "earned" media), owned media (a brand's web presence) & paid media will produce a compound effect if they work together. And that is what Group M saw in their recent study.

A sister company of Ogilvy inside WPP, Group M, released a bit of interesting research a week back. Essentially, their study pointed to the positive effect of social media on the performance of search.

"...a 50% lift in click-through rates across the board when consumers had been exposed to social media and paid search."

"Every day consumers express their intent via search. Now, we better understand how that intent is established via social media and the interplay between the channels," says Chris Copeland, chief executive officer of GroupM Search for the Americas. "There is a valuable audience for advertisers to focus on who are engaged with brands through social media and search. The study further validates our view that media discovery -- specifically. a brand's owned and earned media -- is as important to success as the paid media we handle every day. Generating upper-funnel awareness and influencing consideration through social media can produce better down-the-funnel performance with paid media, such as paid search."

"The study reveals that people who search and engage with social media, especially those exposed to a brand's influenced social media, are far more likely to search for lower-funnel terms than consumers who do not engage with social media. Furthermore, consumers exposed to a brand's influenced social media and paid search programs are 2.8 times more likely to search for that brand's products compared to users who only saw paid search."

The New (and Imperfect) FTC Guidelines Are a Good Start

There has been a fair amount of discussion about the recent FTC Guidelines on Endorsements and Testimonials.I serve as the Board President of the Word of Mouth Marketing Association (WOMMA) and we have been supportive of the FTC's effort to try and protect consumers amidst some pretty fast-paced change in online media. We commented on the proposed Guidelines before they were adopted and pushed back pretty hard on some of the points that seemed to put undue burden on the blogger for product claims they make.

New Responsibility

The final Guidelines do hold bloggers and brands responsible for what they say about products and services and, more importantly, their disclosure to their followers of any material connection between them. The FTC has refined its message over th past week by clarifying that they will look mostly to the marketers to enforce the disclosure requirements.  There are some vague areas. The definition of whether of giving product samples is considered a "sponsorship" hinges on the undefined value of a product (stick of gum? probably not. laptop? oh yes.) and whether there is a history between marketer and blogger or if the blogger has a history of routinely accepting products for reviews. I agree, this is an area that needs to be sharpened if anyone every has a hope of enforcing a guideline.

Not About Advertising; It's About Word of Mouth

But the "sky is falling" claims of some marketers are just not warranted. Randall Rothenberg who heads up the IAB wrote a long, impassioned letter to the FTC Chairman via Huffington Post. I respect IAB and Randall. His book, "Where the Suckers Moon" is one of the best ad books on the market. Their representation of their members is laudable. And if this were all about "advertising" than he might have a point. It's about word of mouth marketing.

As consumers, we have grown used to reading and watching the opinions of peers and 'strangers with expertise'via their blogs, Twitter feeds and facebook pages. This extends the reach of offline word of mouth and together they represent the most trusted source for opinions and purchase decisions around many products and services. That trust is dependent on the transparency of the relationship between marketer and blogger/influencer and the assurance that the opinion a blogger states is truly her own. At WOMMA we want to protect that power which is why we have our own Code of Ethics that guides our members' behavior in this space.

Randall's chief complaint is how the FTC holds online influencers/bloggers to a different standard than traditional media. The former must disclose receipt of products and other considerations that qualify as a material connection. The latter do not. 

I agree this is lopsided. I respectfully request that all traditional journalists disclose when they receive a product from a marketer.(we are really talking about the traditions of the fourth estate not the broader 'communications' field) 

Rather than the IAB stance that hopes to relieve bloggers of any special requirement to disclose, we should really just get everyone to disclose. Let the consumer decide who is credible regardless of whether they write periodically under a recognized media masthead or not. I actually think Mr. Rothenberg is onto something when he says this is confusing. The confusion starts with consumers not always knowing the source of content they browse in the great aggregator - Google. What is traditional media - governed by a journalistic code and what is the emerging media of everyone - which is often oblivious to that code? Rather than treat blogs like traditional media, let's follow a new standard which calls for full disclosure. If journalists and traditional media follow suit, great. If they don't, at least full disclosure by bloggers protects their consumers. I don't seriously think that media companies will jump on the disclosure bandwagon. But if bloggers disclose, they will keep their side of the street clean.  This will protect the power of word of mouth for brands and consumers alike leaving them to collaborate and share about what matters most to them.

The Answer is a Simple Disclosure

The IAB points out many weaknesses in the FTC approach. Their primary concern seems to be whether bloggers will be wrongfully prosecuted for non compliance and whether the Guidelines are constitutional. Sharper minds than mine will debate if there truly is a constitutional issue here. The FTC has already commented that they have no intention of going after bloggers even admitting that they have no real enforcemnt 'engine.' All a blogger has to do to align themselves with the new Guidelines is add a few brief words to their post in a clear way - "they sent me this book (laptop, mobile phone, case of soap, airplane ticket) free of charge to give me an experience with the product. The opinions that follow are my own..."

Let's Define 'Best Practice' Disclosure Next

All a brand has to do is ask them to disclose, monitor if they do and take a reasonable action if they don't. The details of "best practice" disclosure are what we need to iron out next. Rather than rail against the FTC that their current first pass is confusing or worse, unconstitutional, WOMMA will do what it always has done, roll up our sleeves and define the best practice model, in this case, for disclosure between brands and bloggers. Like our Code of Ethics referenced by the FTC, this new guide for how disclosure should be handled by brands may go a long way to satisfy the FTC that the industry really is earnest in protecting consumers. 

Come to our Summit in November to meet the FTC (and FDA!) and participate with our panel as we define very specifically the best way for brands to achieve the highest levels of disclosure. The FTC has started a process. Now they want the industry to continue with the hard work of making it real.  

Social IRM - Influencer Relationship Management Pt 3

or 7 ways you can add scale to an influencer program

Previously, I have covered theresearch and activation of influencers in a Social IRM stratgey. Overall, this is an approach to managing influencers with the same discipline that we try to manage customers - without any of the abuse. By that I mean, the approach to CRM that tries to stimulate customers right to the brink of annoyance but hopefully not over. Like how many emails you send to them with offers before those emails convert to spam. The industry I would most like to see have a CRM overhaul is the magazine business. I am a 15-year or more loyal reader and subscriber to Metropolis Magazine. Do I get any love or acknowledgment? Do they still send me subscription renewals 6 months before they are due hoping that I will think the sub is up and send a check?

Anyhow, the principal of Social IRM is far more benign. It is ultimately built on the premise of 'Value Exchange' covered in a previous post. You cannot 'game' influencers nor can you push them where they don't want to go. The discipline of Social IRM is about serving them better and creating a protocol inside the brand marketer for constantly delivering value that is talkworthy.

Once you have engaged influencers in an experience they care about and they find it worthwhile to post, comment, tweet, video post or otherwise share word of mouth (WOM), how can you add scale to have a bigger impact?

Scale or Amplification
There are 7 key ways to add reach to a influencer program. If there are others, I would love to hear about them. One of the key tenants of Social IRM is that you are engaging relevant influencers on behalf of the brand. This means outdoors experts on behalf of REI or enterprise IT managers for SaS services targeting....enterprise. These folks are not always going to have the largest reach. Certainly they may not have what the professional alpha bloggers have. So the question remains, how can you have their WOM reach more people - without spoiling the WOM?

7 Ways to Scale
Aggregate the voices: If we collect all of what people are saying about the brand or relevant topic and pull it altogether via a content aggregator we can potentially increase the reach. I say potentially because either you will be integrating that aggreagation in a high-traffic site or driving awareness via an ad campaign to the aggregator. Just creating one doesn't do it. Good examples include:

• The Ford Story
• Lenovo Voices of the Summer Games (not active)

Content-driven advertising: A modest ad buy that features the content of the conversation - what people are saying in tweets, comments or posts - can drive new people into the conversation and can also celebrate and reward those who are participating by featuring their conetnt in the ads. If you send the traffic to the aggregator, you can raise the spotlight quickly on what you are doing and create a virtuous circle by making it worthwhile for influencers to contribute to earn visibility for their efforts.
 
Extended influencer outreach: For every 20 influencers in a particular niches that you engage, there may be 20-200 more who would find it relevant to know about what you are talking about and who may want to participate. Extended outreach - done carefully and thoughtfully - can extend awareness via their combined reach.

Traditional media relations: Some of the things we do online are media-worthy.Traditional press may find it interesting that we are co-creating a new product with customers or whatever we are doing. 

Partnerships for reach: Finding a great partner who has a relevant constituency is a fundamental PR and marketing tactic that is equally relevant to the social space. Perhaps the online community around the Appalachian Mountain Club would work with REI on its "Stories of the Appalachian Trail" project (I made this up) and notify their members.

SEO & SEM: Making our content as visible and findable as possible via both organic and a "strategic" SEM buy can ensure that we earn as much search engine traffic for our WOM program as possible. Again, the aggregator is key as a hub that we can build some decent Google Juice around.

An Enthusiast Network: If you maintain long-term relationships with a group of enthusiasts - enthusiasts for the brand or the topic of interest (overnight hiking?) gives you a network of relevant folks to invite into an activity. This can also reduce your cost of "influencer acquisition." We are launching a software platform with several clients now that enables us to grow this type of network and deliver valuable content and offers directly to them for sharing (i.e. this is our value exchange).

Generally no one tactic is the answer. Think of this more as a checklist and all may apply. If you want to go beyond scoring a handful of posts from influencers and stimulate an environment where sharing on a topic is productive for all and reaches as many relevant folks as possible, consider an amplification strategy with these tactics.

Three Important Concepts for Marketers in the New FTC Guidelines

At 81 pages long, the recent FTC Guidelines on Endorsements and Testimonials (and blogger outreach programs) has gained a lot of great attention with a few thoughtful distillations of those 81 pages. Via WOMMA, we were involved when they were first posted for comment. It's great that WOMMA was cited so many times (more than any other organization?) for our best practices. It supports my biased opinion (disclosure: I am Board President at WOMMA) that WOMMA is really the best organization to help guide( and protect brands and marketers who need to operate social media marketing and communications programs).

There is nothing in the final draft that surprises me.As posted earlier, your bets strategy overall is to support a policy of full disclosure by both marketers and influencer to stay both within the spirit and "rule" of teh Guidelines. This is easy for WOMMA members as our own best practice and ethics policies wrote the book on disclosure.  

Still, after a careful read here are 3 big areas that warrant all of our attention:

The Definition of "Sponsored"
I am not nuts about the use of the term "sponsored" by the FTC but I understand why they did it. If you send out a free sample of cookie dough to mombloggers to try the dough and post about if they wish, there are circumstances that would qualify this as sponsorship (e.g. do they regularly receive product to review or does the value of the product exceeds some threshold (not named)). I don't want to get hung up on a word as I do agree that the marketer and blogger should simply reveal that they recieved the cookie dough.

One main reason I am not thrilled with the word "sponsor" is the expectation it breeds on the brand side. "Sponsorship" usually comes with a formal quid pro quo where the marketer gets as much value from the compensated exchange as possible. They don't pay for a chance that their banner shows up on the conference wall. That is part of the package. With most influencer engagements, marketers are providing product experiences hoping that the influencer/blogger will write about that experience. But there is no contract that they will write anything let alone something positive. The pressure is largely on the marketer's side to provide a literally "remarkable" experience. The intent of the FTC is clear and I can see no problem with their desire to have influencers be extra careful about diclosing any material relationship they have with marketers and letting their followers judge their credibility. Remember, the FTC is not trying to prevent endorsments. They are trying to enforce or motivate full disclosure.

"whether the speaker is compensated by the advertiser or its agent; whether the product or service in question was provided for free by the advertiser; the terms of any agreement; the length of the relationship; the previous receipt of products or services from the same or similar advertisers, or the likelihood of future receipt of such products or services; and the value of the items or services received. An advertiser’s lack of control over the specific statement made via these new forms of consumer-generated media would not automatically disqualify that statement from being deemed an “endorsement” within the meaning of the Guides. Again, the issue is whether the consumer-generated statement can be considered “sponsored.”"

Liability of Endorsers
If we engage influencers/bloggers to experience a product or service in the hopes that they will find it worthwhile to share about, we bear some responsibility for what they say most clearly in the claims of product efficacy. The example the FTC uses here is a healthcare claim which is probably the most urgent context as no one wants to see consumers mislead around their health because the context wasn't clear. As Ogilvy has "terms of engagement" for ourselves and those influencers who choose to participate in programs with our brands I am not concerned that the FTC points about liability change much. Our terms require participants to disclose the material relationship, emphasize that their POV is their opinion and make no broad claims of efficacy.

"Nonetheless, if the advertiser initiated the process that led to these endorsements being made – e.g., by providing products to well-known bloggers or to endorsers enrolled in word of mouth marketing programs – it potentially is liable for misleading statements made by those consumers....The Commission is revising new Example 5, however, to clarify that both the advertiser and the blogger are subject to liability for misleading or unsubstantiated representations made in the course of the blogger’s endorsement."

Disclosure of Material Connections Between Advertisers and Endorsers

Both the marketer and the endorser (i.e. influencer/blogger) are responsible to disclose.

"...the Commission believes that the endorser is the party primarily responsible for
disclosing material connections with the advertiser. However, advertisers who sponsor these
endorsers (either by providing free products – directly or through a middleman – or otherwise) in order to generate positive word of mouth and spur sales should establish procedures to advise
endorsers that they should make the necessary disclosures and to monitor the conduct of those
endorsers"

Again,based upon our own best practice this is not a challenge. The trick may be the new requirement to monitor and presumably take action should an endorser not fully disclose as promised. Splitting hairs about whether a particular influencer program qualifies as endorsement or "sponsorship" in the FTC's eyes is not time well spent. If you refer to their definition above for "sponsorship" your best bet is to diclose everything and require disclosure of all of the folks you engage with. The big question remains not how you monitor (that part is easy and we all do it anyhow) but how you enforce a certain disclosure behavior with influencers you have no contract or obligation with. The action they are looking for is some effort to remind the influencer/blogger to properly disclose and then ceasing working with that blogger should they not follow through.

Here is how they frame that issue up:

"the manufacturer has an obligation to advise the blogger at the time it provides the gaming system that he should make the disclosure in any positive reviews of the system. The manufacturer also should have procedures in place to attempt to monitor the blogger’s statements about the system to ensure that the proper disclosures are being made and take appropriate steps if they are not (e.g., cease providing free product to that individual)."
 

Those are the big concepts that affact us on a day to day basis. Again, they are very much aligned with current best practices for marketers like WOMMA members.

other issues covered in the Guidelines:

Celebrity Endorsements: More should be written about a new best practice related to celebrity endorsements. One thing is clear, these guides will motivate celebrities (or their "people") to better understand the claims they may be relating in a script.

Testimonials Reflecting Non-typical Consumer Experiences: Again more shoudl be explored here to interpret the effect of the Guides on marketers. It is clear that the new guideliens remove teh "safe harbor" clause that allows marketers to state "results not typical" when making claims. Claims must be typical. But even here, the FTC allows some wiggle room, "Although the Commission is, admittedly, skeptical that most disclaimers of typicality will be effective in preventing deception, Section 255.2 does not rule out the possibility that a clear, conspicuous, and informative disclaimer could accomplish this goal."

Expert Endorsements: A bigger topic yet one point is that their expertise should be brought to bear upon evaluating the product performance.

Endorsements by Organizations: The goal seems to be that the majority of an organization supports the endorsement.

Some important definitions
According to the FTC Guidelines, here is how they define "endorsement" and "endorser:"

"For purposes of this part, an endorsement means any advertising message (including verbal statements, demonstrations, or depictions of the name, signature, likeness or otheridentifying personal characteristics of an individual or the name or seal of an organization) that consumers are likely to believe reflects the opinions, beliefs, findings, or experiences of a party other than the sponsoring advertiser, even if the views expressed by that party are identical to those of the sponsoring advertiser. The party whose opinions, beliefs, findings, or experience the message appears to reflect will be called the endorser and may be an individual, group, or
institution."

"Endorsements must reflect the honest opinions, findings, beliefs, or experience of the endorser. Furthermore, an endorsement may not convey any express or implied representation that would be deceptive if made directly by the advertiser. [See §§ 255.2(a) and (b)regarding substantiation of representations conveyed by consumer endorsements."

To really dig in to this issue, attend the WOMMA Summit in November where we will have the FTC on hand to participate in a discussion about the nuances and details of the guidleines. (Register now and use code "fanofOgilvy" to recieve a discount on the registration fee.)

The Best Kind of Viral Video: Passion, Strength and Jessica

I wanted to share a personal story about my niece, Jessica Jensen. She is all of 24 years old and a dancer from Pensacola. You can see the story that was published yesterday and the video below. While she was eliminated ultimately from So You Think You Can Dance, I know she can dance. The judge said it best - she reflects "passion, strength and accepatnce

Truth be told, she and her story touch me deeply. I realize that this may be off-topic or my blog but I hope others will appreciate it. It may be that this video and those who would think to share it or otherwise connect with her demonstrate another case of digital influence - exposing the world to a woman who lives in a smaller city in America yet demonstrating more grace than many of us could hope for in a lifetime.

Here is the story and by all means, watch the video:

Jessica Jensen dreams of dancing on Broadway

Social IRM - Influencer Relationship Management Pt 2

or How do we motivate people to get involved and then add reach to their voices? 

Engagement
Marketers are learning that we all need to think in terms of the value delivered to people via our marketing efforts. Now add to that the obligations associated with inviting people to participate with brands in some way that may cause them to share with their social graph - friends, family, fellow dining-out enthusiasts. What will drive people to share word of mouth?

Every time we reach out to influencers, we must think through the "value exchange" - what will they recieve and what will the brand recieve that makes it worthwhile to engage in some way.For Ford, influencers have the chance to drive a Ford car in a somewhat exclusive situation - like the Fiesta Movement "agents" and the drivers who took a Fusion or Flex on their Spring vacation drive. For the BlogHer community, they saw their ideas and in fact, themselves included in the weekly TV show online called The Juice. But they received more than that and every relationship has several possibilities that add up the value exchange.

Value Exchange Ingredients
Here are the building blocks of reciprocal value that can motivate each of us to participate in an influencer program.

1. Social Capital
If you give me a preview of a book, say Nick Cave's The Death of Bunny Munro, then I would likely read it and quickly share my impressions with my friends. If you offered me an interview opportunity that few had with Unilever's Chief Marketing Officer, Simon Clift, I would take you up on it in a minute as I have always admired him and the brand. Each of these examples are social capital that I accrue and can spend with my peers to earn status. It's human. It's not diabolical nor "low." It just is.

2, Spotlight
Simpler than Warhol's 15 minutes of fame, the idea of shining a spotlight on influencers is straightforward. There are influencers all along the Long Tail out there - some quite popular, others popular in their niche, still others who may be on the rise. If we feature their content (with their permission) and profile them, we are celebrating what they do and who they are. Aggregators do this all the time. My content is pulled into Social Media Today. I appreciate that they felt it and me worthwhile. When they feature a post of mine, I benefit. This spotlight conveys status and may also drive other tangible benefits.

3. Traffic
Can brands drive traffic to bloggers and other influencers? The answer is "yes' given the right circumstances. In many cases it is an empty promise. But if a brand is aggregating consumer generated content - the best thoughts out there on adventure travel or family green living - and spending energy and budget to raise awareness and traffic to that aggregation, then the blogger should see an impact.

4. Brand halo
Some brands have a valuable halo. Our client, American Express, has a positive halo effect. The presence and even prestige of the brand rubs off on those associated with it. There are plenty of brands whom I would love to cozy up to for the status that might rub off. Why did I establish a presence in BusinessWeek Exchange? I love the BusinessWeek brand and jumped at the chance to be a part of. Not all brands quailfy and the 'halo' is in the eyes of the beholder, Still, I would be proud to be featured alongside many brands.

5. Value
All of these things could be described as value of some kind. Here I mean tangible value like loaning someone a car for their Spring vacation or giving them case of product to give away to their followers. So long as all parts of this value are fully disclosed by all parties, value can be one of the simplest ways to satisfy another big requirement for WOM - the product experience. People have to have that experience to have anything to share to begin with.   

6. Social Good
Beyond the relevance of the brand and whatever larger platform is going on - e.g. people joining a fuel efficiency discussion alongside Ford - having some social benefit can motivate people as well. If folks know that their involvement will translate into a donation to charity or a much needed relief effort, many will jump in. The hazard here is using a social good motivator as a crutch vs. an organic extension of the experience or brand.
 

Which one of these "values" is more valuable? Which one is the "must-have?" There-in lies the rub. Different people are motivated by different drivers. The best strategy is a net of 3-4 of these value elements to ensure the overall value exchange is strong enough. Cut any one and you might just weaken the value exchange too much.

Next time: Scale & Optimization