Are you playing by the rules with your User-Generated Content?
You can assist your clients in connecting with their community more genuinely than ever by using user-generated content from social platforms such as Instagram and Twitter. When you involve your community in creating content, they become engaged in promoting the brand, helping to raise awareness among their followers.
For instance, the eyewear brand Warby Parker launched a successful user-generated content campaign where they sent five pairs of glasses to customers’ homes for a five-day trial. They asked customers to take photos of themselves wearing the glasses and share them using the hashtag #WarbyHomeTryOn. Customers received input from their friends on which glasses suited them best, while Warby Parker gained free promotion and visibility on social media. A win-win situation!
The use of user-generated content in social media marketing campaigns is relatively new, however, and marketing agencies and departments are still trying to figure out what they need to do to be in compliance with federal rules and regulations.
FTC Concerns
The Federal Trade Commission (FTC) has investigated at least one instance of a company violating the FTC Act in its attempts to showcase user-generated content on the company’s Pinterest board. The alleged violation occurred when Cole Haan started a Pinterest-based contest. Cole Haan encouraged contest participants to start their own Pinterest boards named “Wandering Sole.” To enter the contest, participants had to pin five images of shoes from the company’s Pinterest board along with five place images of their own choosing. The most creative entry would receive a $1,000 shopping spree.
The FTC said that Cole Haan didn’t provide a clear indicator that participants’ pins constituted a contest entry. Section 5 of the FTC Act “requires the disclosure of a material connection between a marketer and an endorser when their relationship is not otherwise apparent from the context of the communication that contains the endorsement.” The FTC didn’t pursue legal action against Cole Haan, but the incidence has caused marketers to take a step back and examine their methodologies and practices.
In this new social media marketing landscape, what can you do to take advantage of the great benefits of social promotions while still staying legally compliant?
Make Your Intentions Clear
To stay compliant when running a social media contest, you must signal that UGC is promotion-driven. In other words, it’s got to be apparent that participants are taking part in a promotion for your company. Hashtags can be an effective, easy-to-use tool for this guideline. By encouraging participants to use hashtags like #ChanceToWin or #Sweepstakes or even the name of the contest everyone is aware that you’re conducting a promotional campaign.
Another way to make your promotional intentions clear is to require the inclusion of specific text in user-generated entries. Under your “How to Enter” text, you could include a requirement that says, “Be sure to say ‘I want to win ___________.'”
Include Proper Disclosures
The Cole Haan ruling made it clear that marketers always need to disclose a material connection if they’re compensating consumers in some way. In other words, if your clients are offering a discount or other incentive when consumers post, pin, or otherwise endorse their brand, this connection must be apparent. This kind of transparency is easily managed by including a specific disclaimer along with the UGC.
With these commonly missed FTC requirements covered, you’re in a great position to help your clients take advantage of the powerful young world of user-generated content. Creatively and wisely used, user-generated content can not only spread a brand to corners of the Internet that were previously unreachable, but it can also give your clients priceless insights into the thoughts, wants, and psyches of their target markets.
When planning your next Instagram contest make sure you’re playing by the rules and download our Instagram Campaign Planning Guide.
