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The Disclosure Policy

Updated on January 20, 2010

Who Needs a Disclosure Policy?

At the beginning of December, 2009, FTC Guidelines were expanded to include blogs and other forms of social media. Such media was probably already under the umbrella of the guidelines, but the recent changes make that coverage more explicit. It's really just a case of organizations who monitor these sorts of things trying to keep up with the technology and the communities that are bred and enabled by that technology.

So, under these guidelines, who needs a disclosure policy? The simple answer is anyone doing business in the US who does promotion and endorsements on blogs, websites, feeds, or other forms of social media. If you blog, tweet, or otherwise post such endorsements, you need to disclose that on your site. If you engage bloggers and other web masters to endorse your products or services, you need to monitor those endorsements and ensure that the whole process is transparent.

The guidelines are meant to cover those who personally endorse or recommend products and services. It would not, then, cover something like a small box or banner on your site for a particular product or service (a renting out of ad space, like a billboard or an old fashioned magazine ad). It would, though, cover anything you say in your posts or website's content that is your own endorsement or recommendation of any product or service.

don't let the new guidelines make you feel foolish...  there's really not a lot to it
don't let the new guidelines make you feel foolish... there's really not a lot to it

What is in a Disclosure Policy?

In your disclosure policy, you need to state that you do, in fact, endorse or advertise on your site. You need to state the extent to which those endorsements will affect the material that you post on the site. Are the topics of your posts sometimes determined by what is being advertised? Then you need to say so. Are you paid to express specific opinions, or only positive opinions? Then tell us that. Any way that your ads might influence your content needs to be made transparent. You can have a look at my disclosure policy as a sample. I started with a template from Disclosure Policy Generator, and modified it a bit to suit my site better. Because I have several blogs and websites that link back to this same disclosure policy, I have given myself the broadest parameters in it that I will ever use, though some of my sites are much narrower than this in what ads they will or won't host. Either way, I have them covered with this policy.

Many of us who are long-time bloggers have had disclosure policies on our sites for a while. The new guidelines don't really change much for us, and really should not be a big change for most bloggers or social networkers. It's really a simple matter to put up a little disclosure policy that meets the guidelines. At the end of the day, it's all only about making our advertising practices more transparent. For those who have been managing their sites well, it really shouldn't be that necessary in the first place, but ultimately, compliance with the guidelines doesn't cost us anything more than a (very) little bit of time to get it set up.

©2009 Shelly Bryant


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