To Tweet or Not to Tweet: When to Disclose a Sponsorship

The FTC has guidelines that mandate bloggers to disclose any “material connection” to an advertiser, including payments for an endorsement, advertising sponsorship or free product.  Since many bloggers promote their posts to their network of Twitter followers, this is where the line gets blurry.

Last night on Twitter I caught wind of a conversation between two food bloggers on Twitter that raised an interesting question to me as both a public relations professional and food blogger.
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At work, it has always been important to me to not only ensure that my client understands these guidelines, but to ensure that the bloggers I reach out to on my client’s dime are aware and respectful of these rules. If I am representing a high-end food product and a blogger whose entire site is covered in product reviews, advertisements and declarations that she is “PR-friendly” that is a red flag to me: this blogger is not someone who wants to provide genuine content to her readers, but rather she’s probably in it for the free yogurt coupons that companies send her.

However, I, like Jeanne Sauvage, have noticed recently that as bloggers are increasingly working with brands as spokespeople and brand ambassadors, they are often having conversations about these brands and their products on social networks. When they write about these items on their blogs, they are required by law to disclose their relationship with a company. When they post to Twitter or Facebook, those rules no longer apply.

As a food blogger and freelance writer, I often receive samples of products – ingredients to try new recipes, small kitchen appliances to test for articles. As a public relations professional who works from a home office, I often have a lot of my clients’ products available to me, too.  The relationship between a blogger contracted by a PR firm or brand to represent a product is not unlike the relationship between a publicist and her client. In both instances, someone is being contracted to perform services (albeit very different ones) to help promote something. In both cases, the relationship should always be prominently disclosed in the media, no matter what.

Disclose if you are a spokesperson for a product. Did a high-end kitchen appliance company reach out to you and offer to send you sample products and monetary compensation in exchange for writing a few blog posts for them? Disclose that relationship in your tweet or post. Is your face plastered all over an online ad for a salsa company in exchange for a hefty check? Disclose that relationship in your tweet or post.

Disclose if a company purchases advertising directly from you. If you sold ad space on your blog to Joe’s Restaurant and you suddenly begin tweeting daily about how much you love Joe’s Restaurant, you need to disclose in those tweets that you have a sponsorship relationship with Joe’s Restaurant. I do think the exception to this is when you are part of a larger ad network and different ads run on your blog at different times. I always review the ads that are running on my blog during a specific month, but I admittedly don’t know which ones are running on a daily basis.

Disclose if you just received free samples. You know the saying, “there’s no such thing as free lunch?” Well, I like lunch a lot, so I think that’s sad, but it’s a little true. When a blogger receives a product from a nice publicist, there is at the very least, a shining glimmer of hope, that they will love it so much that they will tell all of their friends about it. If you like it, go ahead, shout it from the rooftops. Just remember that your readers probably don’t all understand the PR/blogger relationship and won’t expect that you’d received an item for free. If they have to go out and buy your new favorite super special water filtration system with their own money, they should know that yours was complimentary.

Disclose if you feel like you should. Listen to your gut. I work on a brand of baked lentil chips and when I was eating some as a snack a few days ago, I clearly labeled that they were my client in a tweet by adding “[client]” in that Tweet. Have I ever mentioned a client’s product and forgotten a disclosure? Sure, but I wasn’t trying to pull wool over anyone’s eyes by endorsing a product that, well, I get paid to promote. A slip here and there is human, but if you’re a blogger tweeting every day about how much you love your free washer and dryer but you haven’t disclosed yet, it might be time for an ethics class.

What are your own personal guidelines for disclosures in tweets or Facebook posts? Publicists, when do you expect bloggers to disclose a relationship with your brand or client?