FIRST A NOTE ABOUT YESTERDAY....we had one of those days that you dream about- and wake up in a cold sweat. We've never missed an issue, but yesterday was as close as we ever hope to get. We had some "technical difficulties".
If you're reading this with your morning coffee -as many of you are apparently accustomed to doing- things are fine. If not, please rest assured that I am already having a pretty rotten day.
If you were one of the hundreds of readers who inquired about the whereabouts of the Outdoor Wire yesterday - and didn't get a reply from me - it wasn't a personal snub. I simply ran out of hours in the day. It was the first time I not responded personally to everyone who's taken time to write me a note.
Just wanted to let you know what happened that prevented our telling you what's happening in our normal delivery timeframes. In a battle with technology, bet on the technology winning-at least for a while.
A few months ago, I wrote about the Federal Trade Commission announcing it would begin monitoring social media. The goal was to make certain consumers weren't being offered supposedly objective praise -or criticism - when the posts or tweets or whatever, were coming from someone with a connection to the product or manufacturer who was the subject of the discussion.
It's referred to as "word of mouth marketing" and the FTC said it would make certain the things it considered deceptive practices in traditional marketing and advertising were also policed in social media.
Those FTC guidelines included disclosure of all connections between authors and manufacturers, including free products and/or compensation for reviews. It caused quite a stir among social media writers, especially those regularly reviewing product provided by manufacturers. It was the first time anyone had suggested any sort of regulation on the heretofore wide-open area of social media.
Now, the FTC has filed-and settled - the first case under those guidelines against a PR agency charged with engaging in deceptive practices in word of mouth media.
That agency's employees had posed as ordinary citizens while posting game reviews online. They hadn't disclosed the fact the review came from paid employees working on behalf of the game developers.
The FTC case sets a pretty decisive standard: action will be taken against brands, and agencies acting on their behalf, if they are not "open, honest and transparent" in their social media activities. Agencies, incidentally, include individuals who are compensated in some form - including "cash or in-kind payment to review a product or a service"-including bloggers and those who post responses to the blogs.
In an FTC announcement, Mary Engle, the Director of the FTC's Division of Advertising Practices wrote: "Companies, including public relations firms involved in online marketing, need to abide by long-held principles of truth in advertising. Advertisers should not pass themselves off as ordinary consumers touting a product, and endorsers should make it clear when they have financial connections to sellers."
According to the FTC guidelines, advertisers are subject to liability for false or unsubstantiated statements made through endorsements, or failing to disclose a material connection between themselves and their endorsers.
Compensation, in the FTC language, includes direct payments, free products, goods or services (like free hunting trips).
The author/endorser may also be subject to liability for their statements. That means the FTC will require substantiation - or an appropriate basis - for any claims being made via social media.
Legal counsel for the Word of Mouth Marketing Association (WOMMA- and I'm not making this name up) says "as a practical matter, social media and all forms of word of mouth, is now a regulated industry; all stakeholders are responsible for compliance with FTC Guides."
There is, incidentally, a WOMMA Ethics Code to help marketers guide their social media disclosure activities- and it's too-long for a column, but you can read it for yourself at http://womma.org/ethics/code/.
I'm not certain if the monitoring has reached down to Facebook recommendations ("so and so loves Company A -and thinks you will too"), but don't count on my sending you any recommendations.
As a matter of disclosure, The Outdoor Wire Digital Network (The Outdoor, Fishing, Shooting, Tactical and Dealer Wires) is not a WOMMA member.
We are governed under the same FTC guidelines applied to all electronic and print media. We regularly receive products for testing and evaluation -with no guarantees to the manufacturers regarding our findings. We do not submit our editorial product for review to manufacturers prior to making the material available to all our readers. From time to time we find ourselves in the position of having to correct an inadvertent error, but that correction is your assurance that we have not had our material pre-approved by a manufacturer. That goes for products from our advertisers as well. That doesn't mean we don't speak with their representatives if we have a question, that's a part of responsible reporting.
Likewise, the opinions of our editors are just that - their individual opinions. We regularly disagree about products - because we're all individuals. What fits one hand perfectly may be perfectly unsuitable for another.
That's why we never recommend your buying a product -only that you check out one because we liked it. It's the way we've always operated, but we thought that the new FTC ruling made it worth repeating.
As always, we'll keep you posted.
--Jim Shepherd
