Do these guidelines apply to me?
These guidelines apply to anyone who receives something of value, such as a monetary payment or a service or product for free or at a discount, from or on behalf of Smith (even if you gave it away). This can include monetary compensation or service or product for free or at a discount.
Why?
The Federal Trade Commission (“FTC”) in the United States and other legal or regulatory authorities around the world require certain disclosures from individuals who obtain something of value from a brand and comment publicly about the brand.
What do I say?
You must be honest and clearly, truthfully, and prominently tell people what you received from Smith and/or the nature of your relationship with Smith. Use plain language and, if possible, your own voice. Follow the disclosure guidance below.
Disclosure Options
a) Use Plain Language Where Space Permits
Plain-language disclosures may be used up front such as in the main message of the content. For long-form content where the brand mention appears later, the disclosure should be made up front and repeated at the time the brand, hotel or campaign is mentioned or featured.
Acceptable Examples:
- “So excited to work with #SmithHotels on …”
- “Proud to join Mr & Mrs Smith to …”
- “Brought to you by/sponsored by Mr & Mrs Smith
b) Use a Short Form When Space Is Limited
- Short-form or hashtag disclosures can be used where space is limited. Disclosure hashtags should generally appear at the beginning of a string of hashtags. Hashtags that viewers may not always understand – like #spon, #sp or #promo – are insufficient.
- Ensure your disclosure appears before the “more” button. Do not bury it.
Acceptable Examples:
- #SmithHotelsAmbassador
- #sponsored
- #paid
- #ad
Unless otherwise directed, please use the hashtag #SmithInsider along with the disclosures required by these guidelines
Disclosing your relationship with Smith in your “About Me” section on a platform is a good idea, but that alone does not fulfill your specific disclosure requirements.
If you are reposting or sharing a post from one platform to another, be sure that your disclosures travel to the new platform. A good way to ensure this, for example, is including your disclosures directly in a video as well as in the post copy.
If you are giving Smith content to share on its channels or you are sharing content directly to Smith’s channels, you do not need to include these disclosures. If you share that content on your own channels, you do need to include the disclosures.
If you are only providing your endorsement verbally (i.e., no images or visual references to Smith), you must give your disclosures verbally, but on-screen disclosures are helpful too.
Please keep in mind that Smith reserves the right to monitor your endorsements of Smith that you incorporate within your content. Smith reserves the right to cancel any sponsorship or other relationship with you relating to the endorsement of Smith, including if you violate this Policy, the FTC requirements, or applicable law. If you have any questions about the FTC requirements, please refer to the FTC website: http://business.ftc.gov/documents/bus71-ftcs-revised-endorsement-guideswhat-people-are-asking, or contact your point of contact at Smith to discuss this policy or the FTC requirements.
Situation/Platform-Specific Disclosure Placement Guidance
Situation/Platform Placement Photos, Videos, Livestreaming, & Graphics: Disclosure can be in the form of a banner or caption on the screen and/or a title or end card, but do not rely upon disclosure in the written description alone (i.e., not in the video itself). Use on-screen disclosures for videos as many users watch videos without sound. For short videos (3 minutes or less), include the disclosure at the beginning of the video. For longer videos (3 minutes or more) or live streaming, make periodic disclosures or leave the disclosure on screen throughout.
Facebook & Twitter: Disclosure should appear in the copy prior to any links
Instagram: Disclosure should appear in the first 2 lines
TikTok: Disclosures should be in both the video and in the description uploaded with the video (including it only the description is insufficient).
SnapChat / Instagram Story: Disclosure must appear on screen
Pinterest: Disclosure must appear in the main communication prior to clicking.
Blogs: Disclosure must be provided at the beginning of the post prior to any mention of Smith, or any related campaign. If you use other platforms, such as Twitter or Instagram, to notify your followers of a new blog, the disclosure must also appear in those posts if they reference Smith.
YouTube and Other Video: Disclosure should appear:
- In the video description AND on screen or verbally as part of the script at the beginning of the video
- Prior to any mention of Mr & Mrs Smith
If the video is long and the Mr & Mrs Smith reference does not happen until later in the video, the notice of the connection should be repeated, either on screen or verbally in the script.
Periscope & Live Stream: Disclosure must appear several times on screen to ensure that viewers see the disclosure no matter when they begin streaming.
*For any platforms not listed above, please check with your Smith contact for guidance.
Please note: these guidelines supplement, but do not supersede the terms of any existing contract or obligation you may have with Smith. The term “Smith” and “Mr & Mrs Smith” is used herein to refer to Smith Global Limited and any of its affiliates.