Note: The audience for this article is Administrators and Community Managers (known as Program Managers in Classic Studio).

The Federal Trade Commission (FTC) has Guides Concerning the Use of Endorsements and Testimonials in Advertising that companies and its employees must follow. FTC guidelines apply to all employers and employees at all times, regardless of the existence of a managed employee advocacy program.

In this article, we highlight these FTC guidelines and ways you can utilize our platform to help you train, monitor and remind your employees about these guidelines.

FTC Rules for Employee Endorsements

• Employees must clearly share their relationship.
  Employees have an obligation to disclose that they work for a company within their social media posts. This goes beyond a hashtag or including their affiliation within the bio.
• Employers need to train, monitor and remind.
  Employers should establish a formal program to train and remind employees of social media policies. Employee posts without adequate disclosure must be removed or amended.
• FTC enforces fines for violations.
  Companies can pay up to $43,792 per endorsement that does not follow FTC guidelines.

What You Can Do

As Administrators and Community Managers, you have a role to play in making sure employees are using clear and conspicuous disclosures. Employees must use unambiguous language that is clearly noticeable to the audience and is in close proximity to the promotion.

• Engage your legal team and review your current policies and practices around employee/employer relationship disclosures. Make necessary amendments so that you are following FTC guidelines.
• Partner with your social media team to review these policies and practices and ensure you are training, monitoring, and reminding employees about the policies and practices.
• Streamline the “training, monitoring and reminding” by taking advantage of our platforms’ features.

Train. Monitor. Remind.

Train

Train employees on your Social Media Policy and disclosure requirements.

• Ensure your platform’s Terms of Service incorporates your social media policy and the disclosure requirements.
• Use the Welcome Video to communicate your social media policy to new users.
• Make the policy available to workers via a Quick Link, TLC and/or Resource.
• Establish a “social media tips” topic that includes your social media policy and guidance for sharing content.
• Create a recurring email or push notification to deliver the social media policy to new users each week.
• Include a share message when drafting a shareable post so the post will pre-populate for users that discloses their affiliation. *
• Train all employees on a hashtag they should use when promoting your company on social media and use the Appended Hashtag feature to make it easier for employees to disclose their affiliation when sharing content. *
  
  * Some social media platforms (i.e. Facebook) may not allow any other app to pre-populate a post with content that the user didn’t enter.

Monitor

Make a reasonable effort to monitor social media endorsements.

• Quarterly leverage Polls to track how many sharers understand the disclosure requirements and deliver follow-up messaging to users who do not understand.
• Regularly run an Advocacy Insights report to discover which users are sharing content frequently and where they are sharing it.
• Partner with your social media team to leverage available social listening tools regarding posts shared outside of the system.
• Create governance framework and actively enforce your social media policy, particularly when users fail to comply.

Remind

Regularly remind employees of disclosure requirements.

• Annually publish a smart campaign-promoted post that reminds employees of your social media policy and asks them to acknowledge receipt.
• Quarterly publish a smart campaign-promoted post with an acknowledge goal that reminds employees of the FTC disclosure requirement.
• Monthly deliver a recurring email/push notification to users who shared content the previous month, and thank them for their engagement while reminding them of the disclosure requirements.
• Regularly use data from the Advocacy Insights report to target your reminders.