First, what exactly is a disclosure?
A disclosure is the act of making something obvious. In other words, you are divulging the purpose and interests within a published post, whether it be written or otherwise.
By actively using disclosures, you maintain your freedom to write original content, but also maintain an ethical reputation with your readers by revealing whenever something is gifted, paid for, or sponsored. In the United States, there are currently FTC guidelines that state bloggers must disclose the following:
– When you receive a free product and review it
– When you link to the product’s website and receive a commission (called an affiliate program)
– When you receive money, product or services for posting about a product
– When you review a product or service that comes from an advertiser on your site
The FTC’s Endorsement Guidelines are actually very good and very easy to read. You should absolutely read through them yourself, and take note of the specific content types that are relevant to you.
One key thing to observe: It is not enough to simply have a “Disclosure or Terms and Conditions” page on your site as an umbrella. If you’re reviewing a product in a dedicated blog post, you should plan on disclaiming that information *on that very same blog post* regardless of what else you’ve written elsewhere on your site. Here’s a quote from the FTC:
Would a button that says DISCLOSURE, LEGAL, or something like that which links to a full disclosure be sufficient?
No. A hyperlink like that isn’t likely to be sufficient. It does not convey the importance, nature, and relevance of the information to which it leads and it is likely that many consumers will not click on it and therefore miss necessary disclosures. The disclosures we are talking about are brief and there is no reason to hide them behind a hyperlink.
Keep in mind that you don’t have to come up with some elaborate or ugly disclosure that takes over your blog post. You can work in the information naturally. The FTC is very straightforward that there is not “one-way” to disclose, and that as long as it’s obvious to the reader (vague I know) it’s sufficient.
So, how does a disclosure work? Well, for example, take a look at the Valentino all-red Rockstud shoes case study:
In the past, Valentino reached out to bloggers to show off his limited-edition (only 100 were made) all-red Rockstud kitten heels — here is how a handful of bloggers showed off their gift (emphasis ours):
Grit & Glamour wrote: “The elegant house of Valentino gifted me with this extraordinary pair to celebrate the launch of the Valentino Shoe Room (aka your online Rockstud shopping Mecca). The site launches September 24, 2012—get clicking fast, and you could just snag a pair of these limited-edition, red-on-red Rockstud heels.”
Style Scrapbook wrote: “I came back home from London to find this incredible surprise waiting for me … HUGE THANKS to Valentino for my very own first Valentino shoes and to make it even more special, these are the red on red rockstud limited edition pieces, just in time for Paris Fashion Week. THANK YOU VALENTINO!“
Sandra's Closet wrote: “When I arrived at my house, a very special gift from Valentino waited for me that left me speechless: RED ON RED ROCKSTUD kitten heels designed by the house’s Creative Directors, Maria Grazia Chiuri and Pierpaolo Piccioli for the upcoming launch of the ultimate on-line shoe shopping experience, SHOE ROOM.”
Liberty London Girl wrote: “And these arrived this morning: maybe the best gift EVER. A pair of a limited edition of 100 Valentino red Rockstud heels to wear at Fashion Week.”
Atlantic Pacific wrote: (note this was on a post with several other items, none of which required a disclosure) “Shoes: Limited Edition Rockstuds thanks to Valentino. Necklace: Saks 5th (old). Sunglasses: Dior. Jewelry: David Yurman, Sorrelli c/o, Hermes, Jcrew, Pomellato.”
Shoe Snob wrote: “Valentino has dropped a bomb, and in their case, that’s a good thing. A sultry, sizzling, tamale-hot good thing: limited-edition Rockstud slingbacks in fiery red! Only 100 pairs were produced, so a shoe hardly gets more special than this. I have the honor of already securing a pair, thanks to the generosity of Valentino, and they are now the single-most eye-catching pair of shoes I own, hands down!”
If you're still having trouble on what to write for giveaways/sponsored posts/gifted items, here are a few other suggestions:
- Review/Giveaway with no payment: “Financial compensation was not received for this post. A sample product was gifted from _______. Opinions expressed here are my own.”
- Sponsored and/or Giveaway post with payment: “Compensation for this post was provided by _________. Opinions expressed here are my own.”
- If you want to write a full disclosure for your website, but are having trouble, DisclosurePolicy.org let's you click the options that best suit you, and then basically writes the policy for you!
While the FTC themselves have stated that they are “generally not” monitoring bloggers, it’s still just good practice to be above reproach. Treat your readers with respect and they’ll reciprocate. And at this point, just about all professional bloggers are receiving something for free or getting paid to write about products, so it’s just not that big of a deal to let people know when it’s happening on your site. The key is, have integrity and transparency and everyone wins.