Canada’s Ad Standards has released guidelines on influencer disclosure! It’s welcome news to an industry that has been running largely unchecked over the last 5 years. While Ad Standards is not a Canadian government agency, the Competition Bureau in Canada does listen to them closely. As such, these recommendations will likely find their way into enforcement policies in the coming months. It’s also worth noting that this first draft is exactly that, a draft. The recommendations are likely to change somewhat, but they are a solid starting point. Most of the document is developed in a ‘do this, don’t do this’ style, and a lot of it mimics what the FTC enforces in the United States.
Let’s break it down and look at what the recommendations are for disclosure. (You can download the PDF of the document here.)
Who the Influencer Disclosure Guidelines Target
The document outlines three different groups of creators that these guidelines should apply to:
- Blogs and Microblogs. This covers a wide range of creators including bloggers, and those on services like Tumblr, Medium, and Twitter.
- Social Media Networks. Some crossover between things like Twitter and Tumblr, but also includes Facebook, Reddit, and other social media sites.
- Video Content. This is a wide group encompassing YouTube, Twitch, Snapchat, Periscope and other video related content.
Simply, if you’re creating any kind of content digitally that may be brand influenced, these guidelines apply to you.
The Guiding Principle of Influencer Disclosure
Upfront is Best. When in Doubt, Spell it out. That’s what the start of the do and don’t section details. If there’s ANY chance that your content is brand influenced, you NEED to disclose. Being overly cautious about disclosure is the suggestion.
The DO’s of Influencer Disclosure
- DO use #ad. Or #ad in conjunction with #sponsored #BRAND_ambassador #BRAND_partner (Swap brand for the brand).
- DO disclose at the very beginning of your content. If you share a link on Twitter #ad needs to be present BEFORE a link to the blog post. Also, the disclosure must be on every post related to that sponsored content (ie. your disclosure cannot be on the blog post alone.) Also, make sure the first thing in your post is disclosure. It should not be at the end of your post as many bloggers currently do.
- DO disclose clearly even if a platform has a disclosure feature. Instagram and YouTube both have ways to indicate that content is sponsored – but even then, you should disclose within the content.
- DO disclose in the language of the content. If you’re a French Canadian, creating content in French – your disclosure needs to be written in French.
- DO disclose ALL relationships with a brand. In the past disclosure was only when you were paid, but this changes that. You must disclose if you’ve been given something free, an event invite or any other connection to the brand.
The DON’Ts of Influencer Disclosure
- Do NOT use terms that aren’t #ad or other CLEAR disclosure terms. #collab #paid #spon #partner #ambassador are NOT acceptable disclosure methods.
- Do NOT hide disclosure. Your #ad should be clearly separated from the rest of the hashtags. It should be mentioned immediately, rather than at the end of a post. Clear and conspicuous.
- Do NOT opt for Blanket Disclosure. Some creators say “Some of my content is sponsored”, but that’s not enough. Each individual post needs to be disclosed independently.
- Do NOT be ambiguous in your words. “Thanks to X Brand” does not constitute disclosure and is not acceptable.
Disclosure Guidelines for Individual Services
- YouTube: Disclosure should be both VERBAL and VISUAL in the first 30 seconds of a video. You can watermark #ad (in a conspicuous way) to cover VISUAL, and VERBAL must be said allowed that the content is sponsored. You also need to include #ad in the description of the video.
- Instagram: Disclosure MUST be at the beginning of a post. The nature of the relationship must be obvious, for example, if it’s paid use #ad. If you’ve been gifted product, declare #GiftedProduct or #ProductProvided. If you’ve attended an event put on by a brand, disclose that.
- Instagram Stories / Snapchat: Operates the same way as Instagram posts – disclose! It should be both VISUAL and VERBAL disclosure.
- Twitter: #ad must be disclosed BEFORE you link to additional content.
- Blogs: Your disclosure must be at the very TOP of your post. You cannot hide them in the bottom. The disclosure must be clear what your relationship is – #ad? #ProductProvided? etc.
Our Thoughts on Ad Standards Influencer Disclosure
While I’m happy that Ad Standards has put out these guidelines, there’s a LOT that needs to change. Simply put, they have taken disclosure and made it overly complex. While SOMETHING is better than nothing, disclosure needs to be straightforward. They need to clean up the language. They hit on the fact that disclosure needs to be clear and concise, yet have created a document that is absurdly unclear. Their ‘examples’ section is a mess of confusion (despite knowing what they are getting at), they still managed to make it complex.
The WORST Part of this Document
The worst part (the ironic part?) about this document is that THEY DON’T DISCLOSE WHO CREATED IT. You’ve created a document about disclosure, but haven’t CLEARLY and CONSPICUOUSLY disclosed who YOU are. It’s not until PAGE 36 (the second LAST page) that you find out it was created by something called the “Influencer Marketing Steering Committee”.
- #Paid (Co-Chair), an influencer marketing company.
- Cision (Co-Chair), a PR firm.
- Faulhaber Communications, a PR firm.
- National, a PR firm.
- Veritas, a PR firm.
- Strategic Objectives, a PR firm.
- Dulcedo Management, an influencer agency.
- INF, an influencer agency.
- Shine Influencers, an influencer agency.
- Studio 71, an influencer agency.
- The Influence Agency, an influencer agency.
- Kin Community, an influencer agency.
- Le Slingshot, an influencer agency.
- Viral Nation, an influencer agency.
- Food Bloggers of Canada, an influencer network.
- Influence Central, an influencer marketing company.
- Influicity, an influencer marketing company.
- Izea, an influencer marketing company.
- Made In, an influencer marketing company.
- Interfluence, an influencer marketing company.
I’d like to see how this document came together, who made what recommendations and how it was approved. While it is important to have influencer companies at the table – CREATORS are not being represented here. This is PURELY the business people at the table, and not the front line creators having a say in this. Which is a huge problem.
Bring Creators to the Table
It’s important that our voices are heard in this matter. Make no mistake, clear disclosure is an absolute must – and there are many creators who simply do not do it. There’s no defending that. But, what we need to see is detailed guidelines that work for everybody.
They should open feedback forms for creators to weigh-in directly. OR at the very least, bring creators into the committee to be involved in this process.