June 15, 2010
How To

Follow the FTC’s Street Team Guidelines: 4 Recommendations for Offline and Online Promos

SUMMARY: The FTC’s updated Guidelines on endorsements and testimonials affected more than blogger relations and product claims. The guidelines also govern the use of street teams.

Read how and when your street teams should make disclosures to avoid FTC scrutiny. Includes four recommendations from word-of-mouth marketing experts.
The Federal Trade Commission’s updated Guidelines Concerning the Use of Endorsements and Testimonials, made effective in December 2009, had broad implications for marketers’ relationships with bloggers and celebrities, and the product claims they make.

But marketers may not have noticed that the guidelines also addressed street team marketing.

The guerrilla marketing tactic of recruiting brand evangelists to stir up buzz, both online and offline, is addressed specifically in a single paragraph (see useful links below). Essentially, team members who receive incentives such as cash or "points" redeemable for prizes need to disclose such incentives when promoting, and marketers have to take steps to ensure those disclosures are made.

"The FTC’s guidelines shouldn’t change a thing for anyone who’s good at what they’re doing and who is doing it the right way," says Terry Dry, President, Fanscape, a digital word-of-mouth marketing agency. "Really what they’re saying is that you better be transparent and you better disclose what you’re doing."

We spoke with Dry and Sara Soseman, President, Department Zero, an offline word-of-mouth marketing expert, to better understand the guidelines’ impact on online and offline street teams.

Below are the key areas they highlight to keep your brand safe and your company out of legal hot water.

(Please note: We are not lawyers. Any changes to your strategy should not be based on this article alone. Be sure to speak with your attorney.)

Recommendation #1. Start with a sound strategy

The guidelines emphasize that material connections between a company and a street team member must be disclosed. This explicitly prohibits hiring teams to "secretly" promote a product or company without disclosure.

- Building trust is vital

Strategies that rely on deception will inherently put a brand at risk. Soseman and Dry suggest avoiding them.

"Our job as an agency is to help build brand and strengthen consumer experiences with the brand," Soseman says. "It’s never in our clients’ interests to do anything that can be construed as unclear or dishonest."

Recommendation #2. Hire and train team members well

Both Soseman and Dry emphasize that hiring just anyone to be a brand evangelist is not a sound strategy. Instead, they look for people who understand the product or brand they’ll be promoting.

Having a knowledgeable team helps engender trust in the audience, and it can help you reach the team’s like-minded friends and followers. But more importantly, hiring knowledgeable staff ensures they’ll know what they’re talking about.

The FTC’s guidelines emphasize that a company is liable for any product claims made by its promotions -- which includes street team members’ statements. Opinions, such as "This is the best candy I’ve ever had," are acceptable, Dry says, but factual inaccuracies are not.

- Where to find team members

For online team members, Dry looks for people who have established themselves as an online authority. They might be blogging or managing a Facebook group on a topic directly related to his client’s product.

Soseman hires professional brand ambassadors she finds through online classifieds postings and industry websites, such as Event Speak (see useful links below). Once she finds a good team member, she asks for referrals.

- Provide training on products and brands

Training team members on product and brand details is vital. Make sure your members understand the typical questions people will ask, and that they know how to answer them. Also make sure they avoid making false claims, because you can be held liable.

Soseman’s team holds training programs for all products they promote. Training someone to promote a food sample might last an hour, whereas training to promote a feature-heavy product, such as a new car, is likely to be an ongoing process, she says.

Recommendation #3. Enforce transparency and disclosure guidelines with your team

Any team members you compensate with products, points or pay must disclose that relationship to the people they reach.

The Word of Mouth Marketing Association (WOMMA) has a Social Media Marketing Disclosure guide with specific sentences you can use online (see links below). And Dry and Soseman have the following suggestions:

- Direct disclosure

The simplest way to disclose a relationship is to come out and say it, whether in person or online. If asked, street team members should say "I am working for [brand x]" or "I am working for a marketing company on behalf of [brand x]."

If your team members are given free products for their training, such as a brand-provided phone, they should make the disclosure when discussing the product, such as "[brand x] provided me a phone, and I’m impressed with it."

In a one-on-one situation, you only have to make the disclosure once, Dry says.

"If you keep disclosing the same thing, you’ll seem almost like a robot and I won’t trust you."

- Links to disclosure pages

In some online channels, it can be more convenient to link to a disclosure page. In Twitter, for instance, messages cannot exceed 140 characters, so a typed disclosure would defeat the purpose of sending a message.

WOMMA suggests people sending sponsored tweets use a short-link URL to a disclosure page and one of the following hash-tags to signal to readers that the post is sponsored:
o #spon (sponsored)
o #paid
o #samp (sample)

- Clothing and signage

In offline street teams, Soseman suggests members wear clearly branded clothing and also have branded signage nearby. This helps support transparency around the members’ motives, and also helps engender trust.

"If someone passing in the street handed you a food sample, you’d want to know where it was coming from," Soseman says. "If you’re going out with the brand all over you, it’s pretty clear that you’re representing the brand directly."

Recommendation #4. Monitor teams’ activities

One of the most difficult parts of the FTC’s requirements is the level of monitoring required. Checking every street team-based conversation is impossible, but your team should do what it can to ensure your brand is not being tarnished, and that you’re staying within the guidelines.

Here are some tactics for monitoring online:
o Customize and track promotional links sent to each team member
o Customize and track coupon codes
o Ask members to provide screenshots of mentions and endorsements
o Ask members to provide periodic reports of their work with links to examples

Monitoring offline can be even more challenging, which makes your hiring and training processes vital safeguards against mistakes. Soseman’s team employs "field coordinators" who act as managers, making sure team members take the correct actions.

Useful links related to this article

Members Library -- FTC’s New Endorsement Guidelines: 6 Key Areas to Examine

Members Library -- Viral Website and Street Team Strategy Shatters Lead Gen Goal: 6 Steps

Members Library -- How to Build an Online Street Team to Create Viral Buzz

FTC: Guides Concerning the Use of Endorsements and Testimonials in Advertising

WOMMA: Social media marketing disclosure guide

Event Speak: Event marketing community

Department Zero


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