Post on 27-Apr-2018
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WITH YOU TODAY
Janet Helm, MS, RD Chief Food and Nutrition Strategist, Weber Shandwick
Co-Founder, HealthyAperture.com
and Nutrition Blog Network.com
Blogger: Nutrition Unplugged,
U.S. News & World Report
jhelm@webershandwick.com
@JanetHelm
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FUNDAMENTAL PRINCIPLES
The dietetics practitioner:
Conducts himself/herself with honesty, integrity and fairness.
Supports and promotes high standards of professional practice.
Accepts the obligation to protect clients, the public and the profession.
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Academy of Nutrition and Dietetics
Code of Ethics for the Profession of Dietetics
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The dietetics practitioner:
Does not engage in false or misleading practices or communications (#6).
Protects confidential information and makes full disclosure about any limitations on his or her ability to guarantee full confidentiality (#10).
Presents reliable and substantiated information and interprets controversial information without personal bias, recognizing that legitimate differences of opinions exist (#13).
Is alert to the occurrence of a real or potential conflict of interest and takes appropriate action whenever a conflict arises (#15).
Does not invite, accept, or offer gifts, monetary incentives, or other considerations that affect or reasonably give an appearance of affecting his/her professional judgment (#18).
Academy of Nutrition and Dietetics
Code of Ethics for the Profession of Dietetics
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ETHICAL ISSUES RELATED TO BLOGGING
Considered a “publisher” with ethical
responsibilities of a journalist
Original content, reliable sources
Distinguish between advocacy,
commentary and factual information
Disclose conflicts of interest,
affiliations, activities and personal
agendas
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OPPORTUNITIES FOR DIETITIANS
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Potential “asks” that require disclosure:
Join our ambassador program
Use our product, document your
experience
Create content (sponsored blog
posts, recipes, videos)
Enter our contest to win prizes
Share on your social networks
Comment on other blogs
Host a Twitter party
WHY?
It’s the right thing to do
It’s part of our professional code of ethics
It’s now required by the FTC
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WHAT IT DEMONSTRATES
Trust and transparency
You have nothing to hide
You respect those in your social networks
You’re a responsible partner
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Endorsements must be truthful and not misleading.
If the advertiser doesn’t have proof that the endorser’s
experience represents what consumers will achieve by using
the product, the ad must clearly and conspicuously disclose
the generally expected results in the depicted circumstances.
If there’s a connection between the endorser and the marketer
of the product that would affect how people evaluate the
endorsement, it should be disclosed.
TRUTH IN ADVERTISING
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Cash or In-Kind
Payments
Free Product
and Samples
Free Trips
Contests /
Giveaways
Sponsored Posts
Product Reviews /
Free Samples
Employer/Client /
Sponsor
Reference
MATERIAL CONNECTIONS
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AS A BLOGGER YOU SHOULD HAVE…
A disclosure policy or statement on your blog or website
Disclosures within a blog post
Disclosures when sharing information on your
social networks or in media interviews
Documentation of your partnership
with a company or brand
Don’t worry, I’’ll show you what these look like
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A MARKETER’S RESPONSIBILITY
It’s the brand or advertiser’s responsibility to inform the
bloggers they’re working with about transparency and
disclosure
• Guidelines typically written into a contract
A company will monitor to check what brand ambassadors
are saying about their products, looking for proper disclosure
• Will follow-up if disclosures are not consistently used
Both parties are responsible to abide by FTC guidelines
• But ultimately YOU are accountable
• It’s your responsibility to be familiar with online
endorsement guidelines
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Use clear notations to
describe any material
connection
• #client
• #sponsored
• #ad
• #sample
• #paid
WHAT DISCLOSURE LOOKS LIKE
To ensure proper disclosure
on social media:
Write separate posts for
each individual social
platform, as #hashtags and
@tagging often don’t
translate.
BEST PRACTICE – SEPARATE POSTS
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I received [product/sample/information]
from [company name].
[Company name] sent me [free products/coupons].
I was paid by [company name] to review this
[product] or create this recipe.
By posting this recipe, I am entering a contest
sponsored by [company name].
I am an employee (or representative) of
[company name].
I would like to recommend my sponsor,
[brand/company name].
This post is sponsored by [company name].
BEST PRACTICE – CLEAR LANGUAGE
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“Do I need a
disclosure statement or hashtag
… or is a page on my website enough?”
BEST PRACTICE – PROMINENT LANGUAGE
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When not restricted by character count,
be transparent and use full and clear communication.
On-Air, Facebook, Instagram, Google+, Pinterest, etc.
#Ad: My peanut butter bar
recipe is gr8 snack for kids.”
“This post is #sponsored by
@companynametag”
“I am employed by
@companynametag”
DISCLOSURE: BEYOND THE BLOG
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If restricted by character count (e.g. Twitter), spell out hashtag
completely and tag company sponsoring/paying:
#sponsored
#client
#paid
#ad
#sample #freesample
@companyhandle
SOCIAL CHANNELS
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If you are paid specifically to write a post,
use #Ad at very beginning of post.
According to FTC, consumers should be
told up front when they are being
advertised to.
Because posts get cut off when being
retweeted/shared, #Ad is required at
beginning to ensure full transparency.
SOCIAL CHANNELS
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You have a material connection when attending
a sponsored trip or event.
Indicate with every post that the trip or event
is #sponsored
Tag the company paying for trip, sponsoring
the event
Do not abbreviate #hashtags or use vague
#hashtags
#Cauliflower is not clear and transparent; is
it commodity board, branded product or
university paying for the trip?
SPONSORED TRIPS
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No character count restriction:
“Having a blast in California on the
#cauliflowerfarmtour. #Sponsored trip
by @companyhandle”
Restricted character count:
“Learning how #cauliflower is grown.
#Sponsored by @companyhandle”
SPONSORED TRIPS
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Disclose any material connections to
your editor
Clearly disclose connection within
body of article or in your author‘s bio
If you write for a publication that
doesn’t accept sponsored content or
won’t disclose relationships, do not
write about the products/services of
your clients, even if client isn’t paying
you to incorporate messages into that
particular article
WHEN WRITING FOR MEDIA
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Disclose material connections to producer during pitch
Verbally disclose relationship during on-air segment
For print interviews, disclose material connections to person interviewing you (do it in writing so there’s proof of your disclosure)
Be proactive in providing wording that mentions the material connection, such as a “consultant to…”
Disclose relationship when sharing media clips or photos on your social channels
MEDIA INTERVIEWS AND VIDEOS
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DISCLOSURE POLICIES
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Create a section on your blog or
website that identifies all
marketing relationships and
financial interests
Should be prominently featured
on blogs, not buried within a site
This is not a replacement for
disclosure in individual posts
Ann Taylor LOFT invited bloggers to attend an
exclusive preview of its new summer
collection. “Bloggers who attend will receive a
special gift,” the invitation read, “and those
who post coverage from the event will be
entered in a mystery gift card drawing where
you can win up to $500 at LOFT!”
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In small print on the invitation:
“Please note all bloggers must post
coverage from our event to the blog
within 24 hours in order to be eligible.
Links to posts must be sent to [email
address] along with the code on the back
of your gift card distributed to you at the
event. You will be notified of your gift
card amount by February 2. Gift card
amounts will vary from $10 to $500.”
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“We were concerned that bloggers who attended a preview on January 26, 2010 failed to disclose that
they received gifts for posting blog content about that event.”
Mary K. Engle
Associate Director of Advertising Practices
Federal Trade Commission
April 20, 2010
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What Was the Resolution?
FTC ultimately determined not to recommend an enforcement action
because it was the first and only such preview for bloggers; very few
bloggers posted content from LOFT and some did disclose.
LOFT adopted a written policy stating that the company would not issue
any gifts without first telling bloggers that they must disclose the gift in
their blog.
FTC said it will expect the company to “take reasonable steps to
monitor bloggers’ compliance with the obligation to disclose gifts they
receive from LOFT.”
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RESOURCES
Ethical and Legal Issues Related To Blogging and Social Media May 2013; 113:688-690.
http://www.rds4disclosure.org/
http://business.ftc.gov/documents/bus71-ftcs-revised-endorsement-guideswhat-people-are-asking
http://cmp.ly/
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TRUE or FALSE?
A comprehensive online disclosure policy on your blog or website fully covers you.
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You must disclose your affiliation with a company or product within a blog post
and in all your social networks. Each time you Tweet or post on Facebook, for example, you need to disclose this “material
connection” by indicating #sponsored, #client or #ad.
Your relationship – even if simply free products
were provided – must be mentioned within the individual blog post, not just in
your disclosure statement.
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TRUE or FALSE?
You have a contract with a food brand to serve as a spokesperson or advocate. You are writing a blog post that recommends this product. Since
you were not paid for this specific mention you do not need to disclose.
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TRUE or FALSE?
You are a member of an advisory panel for a food commodity board and receive a yearly
honorarium. You start a Pinterest board that features this food You should disclose your
relationship on Pinterest and your blog.
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TRUE or FALSE?
You conducted a satellite media tour on behalf of a food brand, and were paid to write a blog post. If you mention that you were paid in your post you do not need to disclose on Facebook if you share
a media clip of your interviews.
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TRUE or FALSE?
A blogger not in compliance with the FTC guidelines may be fined up to $11,000.
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TRUE or FALSE?
You attended a sponsored event where a food company presented promotional information about
a product. Because you weren’t paid, you don’t need to disclose anything in your tweets or
Facebook posts.
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TRUE or FALSE?
If a restaurant “comps” you for a meal without you asking for it and you write about the
experience, you don’t need to disclose.
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TRUE or FALSE?
You have a year-long contract with a company and have been asked to comment on different blogs
that are critical of this food or beverage. You need to disclose that you're working with this company
when adding comments.
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TRUE or FALSE?
You are being paid to do a Twitter chat for a client, or you’re a consultant to a food company or
commodity board and they’ve asked you to be the guest expert for a Twitter chat.
You should disclose with every tweet.
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