Ad Standards Influencer Marketing Steering Committee Disclosure .

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Influencer MarketingSteering CommitteeDisclosureGuidelinesUpdate: Fall 2020

From Ad Standards’ Influencer Marketing Steering CommitteeAd Standards, in collaboration with an industrypanel of influencer marketing companies, presentsthese Disclosure Guidelines to illustrate industrybest practices. The guidelines that follow are meantto educate the influencer marketing industry abouttheir disclosure obligations and to provide apractical framework for providing disclosure.The members of the Ad Standards Influencer Marketing Committeehave come together from across the influencer marketing sector toset out a practical set of guidelines and tools to provide clarity onhow, when, and what to disclose when engaging in influencermarketing on any social media channel.With rapidly evolving technology and marketing trends, it isimpossible to predict every possible scenario. This is intended tobe a living document that will be regularly updated. We inviteyour comments and feedback at info@adstandards.ca.These guidelines do not replace or supersede regulatoryrequirements on influencer marketing that exist in certain sectors.Further, the disclosure best practices that follow in this document donot constitute legal advice nor do they ensure compliance with theCanadian Code of Advertising Standards or the Competition Act onmaterial connection disclosure; product performance representationnot based on adequate and proper tests; nor false or misleadingrepresentations. The full context of any communication must alwaysbe considered to determine what may be required.2INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESApplicationPlease encourage members of your team, from the inception of anyinfluencer marketing campaign, to use these Disclosure Guidelinesas a roadmap for providing truthful, fair, and accurate influencermarketing content.The Disclosure Guidelines apply to anyone involved in influencermarketing practice. It is important to note that the same principlesunderling these industry best practices may apply in contextsoutside of influencer marketing. For more information, see ourdiscussion about the Canadian Code of Advertising Standards onPage 4 .ContentThe Disclosure Guidelines cover: Regulatory Landscape3 Self-Regulatory Framework4 Definitions5 The Do’s and Don’t’s of Disclosure6 Examples of When to Disclose22 Affiliate and Refer-a-Friend Marketing24 Specific Media Channel Disclosure Examples27 Current Influencer Marketing Committee Participants41 Learn More42

Regulatory LandscapeIn Canada, the Competition Bureau is theprimary government body responsible forenforcing laws about misleading marketingpractices. An arm of the federal government,the Competition Bureau oversees theCompetition Act with the goal of preventingfraud and eliminating deceptive marketingpractices.Shared Responsibility for ComplianceBreaching the Competition Act can result incivil or criminal action by the CompetitionBureau (see Sections 52 and 74.01 of theCompetition Act). The misleading advertisingand deceptive marketing provisions apply toinfluencer marketing just as they do to anyother form of marketing. While nothing iswrong with advertisers compensatinginfluencers, or with influencers acceptingcompensation, both parties to theserelationships need to remember that they aremaking marketing representations toconsumers.The Competition Bureau has a webpage dedicated toinfluencer marketing g/04512.html.3INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESThe onus for mandatory disclosure compliance ison all parties involved in the influencer marketingcollaboration. There is a shared burden on anyagency, PR firm or company responsible forfacilitating the sponsorship - in addition to thebrand advertiser and influencers involved.The Competition Bureau also published a detailed guide forinfluencer marketing in The Deceptive Marketing Practices Digest- Volume 4, available cb-bc.nsf/eng/ 04372.html#sec01For additional resources, including the U.S. FTC’s and otherself-regulatory organization materials on influencermarketing, see the Further Reading section.

Self-Regulatory FrameworkAd Standards, the Canadian advertising industry’sself-regulatory body, administers The Canadian Code ofAdvertising Standards (the Code). When a consumercomplaint about influencer marketing gets evaluated byAd Standards or is adjudicated by the Standards Council(Council), there are several provisions of the Code that comeinto play. Council meets once per month and is composedof representatives from the advertising industry and thepublic who volunteer their time to support the consumercomplaint process.Accuracy and ClarityWhen considering a complaint about an advertisementand whether there has been a contravention under the Code,the general impression conveyed by the advertisement isassessed. Under Clause 1, Accuracy and Clarity,advertisements must not omit relevant information if theomission makes the advertisement deceptive or misleading.In the case of influencer marketing, omitting a disclosureof a material connection may be considered misleadingadvertising and could result in a violation of Clause 1(b)and 1(f).Disguised AdvertisingTechniquesClause 2, Disguised Advertising Techniques, statesthat an advertisement cannot be presented in a way thatconceals the fact that it is an advertisement. In theGuidelines that follow, there are many examples givenfor a variety of platforms that demonstrate how to avoidcontravening this Clause by using upfront disclosures.4INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESTestimonialsAnd finally, the last relevant section of the Code is Clause 7,Testimonials, which requires that testimonials, endorsements or otherrepresentations of opinion or preference, must reflect genuine andcurrent opinions and be based upon adequate information. To enhanceindustry and public understanding of how to interpret and apply theCode, Ad Standards develops Interpretation Guidelines. InterpretationGuideline #5 provides guidance on disclosure that is required in orderfor a testimonial, endorsement, review, or other representation (in anymedium) to comply with Clause 7 of the Code. The Guideline statesthat a testimonial, endorsement, review, or other representation mustdisclose any material connection between the reviewer and the entitymaking the product or service available. If such a material connectionexists, that fact and the nature of the material connection must beclearly and prominently disclosed. These principles apply to influencermarketing, as well as to any to other instance where there is a materialconnection between the reviewer and the entity making the product orservice available, such as employer-employee relationships or familyrelationships. Similarly, affiliate marketing and refer-a-friend programsmay also trigger disclosure requirements where the individual isreceiving compensation or other benefits for making the referral.Ad Standards is a member of The International Council for Ad SelfRegulation (ICAS), a global platform which promotes effectiveadvertising self-regulation. Canada is among the countries with selfregulatory codes and guidelines for influencer marketing. ICASincludes these Guidelines in its online overview of the many ICASmarkets worldwide that have guidelines to ensure transparentdisclosures in influencer marketing. For the complete list, see theFurther Reading section.

DefinitionsTermAdvertisingDefinitionsThe disclosure guidelines apply to all exchanges of value between an advertiser—or a party working on behalf of an advertiser—and an influencer. This mayinclude free products, monetary exchange, or other perks with the expectation—explicit or implied—that a promotion or inclusion of the advertiser’s products in apost occurs."Advertising" and "advertisement(s)" are defined as any message where the content is controlled directly or indirectly by the advertiser and which is communicatedin any medium to viewers with the intent to influence their choice, opinion, or behaviour.5Affiliate Marketing(or network marketing)A marketing strategy whereby one party receives a commission (or something else of value) for generating traffic to the other party’s website, page, post or othercontent. This may be accomplished through links, tags, or through any other means that drives consumers to the promoted brand’s content.BrandThis includes the professionals who work with the advertisers and their affiliated parties, which may include media agencies, PR agencies, creative agencies, orinfluencer marketing companies that work with them.Brand Ambassadorship orExclusivityA material relationship for a long-term engagement, including employment, often with both defined and undefined content production and distribution expectations.This typically includes roles, responsibilities, deliverables, and a set time period outlined in a contract.InfluencerSomeone who possesses the potential to influence others, regardless of the number of followers or viewers they may have. The people whom influencers affect aredefined as a person or group who take action or change opinion/behaviour as the result of exposure to information provided by an influencer. This may occur on ablog, social media website, or other media publications. Influencers may also be known as ‘Talent’ or ‘Content Creators’.Material Connectionand any employment,personal, or familyrelationshipAny connection between an entity providing a product or service and an endorser, reviewer, influencer or person making a representation that may affect the weightor credibility of the representation, and includes: benefits and incentives, such as monetary or other compensation, free products with or without any conditionsattached, discounts, gifts, contest and sweepstakes entries, and any employment relationship.PaymentPayment means any form of consideration, including financial compensation or other arrangements, such as provision of free products (see definition of MaterialConnection).INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

The Do’s and Don’tsof Disclosure6INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Upfrontis best.Disclosures are meant to providetransparency and honesty of all viewersof the sponsored post.Each of these best practices areintended to catch the viewer’s attentionand ensure the disclosure is clear,conspicuous, and broadly understood.7INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESWhen in doubt,spell it out.The Disclosure Guidelines are not intended to beprescriptive, as it is difficult to keep up with rapidlychanging social media platforms and viewer habits.Should you be using a platform not mentioned in theseguidelines, or encounter a situation outside its currentscope, please continue to apply the principles thatdisclosure is necessary and must be clear, conspicuous,and broadly understood.

Do:Disclosuresshould be clearand usewidely acceptedhashtags#8INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESHashtags that have been recognized asclear and widely accepted include:EN: #ad, #sponsored, #XYZ Ambassador,#XYZ Partner (where “XYZ” is the brand name)In contrast, if a team combined a companyname, such as “Cool Stylle” with “ad” tomake “#coolstyllead”, there is a goodchance that viewers will not notice andunderstand the significance of the word“ad” at the end of a hashtag, especiallyone made up of several words combinedlike “#coolstyllead.”Other unclear hashtags include:#Ambassador, #Partner, #Spon, #PR, #Promo,#PRHaul, #Brand, #Collab, #sp.The nature of the material connection isnot clear, and these terms are subjective.

Don’t:Hidden DisclosureEffective Disclosure Tips If a creator uses a lot of hashtags/mentions at the endtheir content, then the disclosure should always beprior to those hashtags/mentions. If disclosures are buried in a hashtag list; or are inoverlays that are too small or faint, they could beconsidered hidden. Disclosures need to be clear and conspicuous.Highlightsin the Example 9While this endorsement included the disclosure #ad, itwas buried below the main message of the post andincluded in a hashtag list that does not make thedisclosure clear and conspicuous.INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESzz

Do:Disclosures shouldbe independentof social medianetwork or channelspecific settingsMany social media platforms offer afeature to disclose an advertisingrelationship, but there is no guarantee itis an effective way for influencers todisclose their material connection to abrand. It still depends on an evaluationof whether the tool clearly andconspicuously discloses the relevantconnection.The disclosure should catch viewers’attention and be placed where they arenot likely to miss it. A key considerationis how viewers see the screen whenusing a particular platform.Social networks may require the use oftheir disclosure features, but thosefeatures should be used together withother disclosure best practices. Thiswill also help ensure disclosurestransfer to all platforms.10INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Do:In videos,disclosuresshould be upfrontand identifiableThere is no guarantee that viewerswill read, hear or see a messageunless it is presented prominently atthe beginning of a piece.It is more likely that a disclosure atthe end of the video will be missed,especially if someone does notwatch the whole thing. Having it atthe beginning is a more effectivedisclosure method. Having multipledisclosures during the video is mosteffective.Disclose before the viewer needs toclick for more (i.e. in the first couplelines of the post).11INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Do:Disclosuresshould be made inthe language ofthe endorsement12INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESThe connection between an endorserand a marketer should be disclosed inwhatever language or languages theendorsement is made, consistent withthe viewer’s interpretation. If thecontent and captions are in French,disclosures should be made inFrench. Likewise, if the content is inEnglish, disclosures should be madein English.

Don’t:Blanket DisclosureEffective Disclosure Tips Blanket disclosures in a profile/bio/about section mayfall below the recommended standards for disclosuresbecause people visiting the site might read individualreviews or watch individual videos without seeing thedisclosure on another page. Many readers may not see this blanket disclosureclause and may not clearly understand the relationshipbetween the advertiser and influencer.Example Highlights 13This blanket disclosure does not meet the standard ofmandatory disclosures because each individuallysponsored post is not connected to a specific brand orproduct , and does not describe the nature of thematerial connection.INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES“Where I have receivedmerchandise from a company, Imake that clear in the copy of thepost or in the outfit details bymarking it “c/o”. Where I havereceived monetary compensationin return for promotion, I disclosethat the post was sponsored in thebody of the post. While I attempt tomake this as clear as possible onmy social media channels, theabbreviated nature of a mediummay impact my ability to do so.”

Do:Disclosuresshould be in closeproximity to theendorsementThe disclosure should be as close aspossible to each message and placed insuch a way that it travels with themessage. This means including adisclosure before a URL (clickable ornon-clickable), ensuring that sponsoredbrand mentions are seen with thespecific disclosure, and ensuring itmakes contextual sense. Include thedisclosure in each post, in the video(where applicable) and not just in thecomments.Conversely, a single blanket disclosurein a separate profile/bio/about section,such as “many of the products I discusson this site are provided to me free bytheir manufacturers” does not meetmandatory disclosure criteria becausepeople visiting the site might readindividual reviews or watch individualvideos without seeing the disclosure onanother page.14INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Do:Disclosuresshould be specificabout the brand,product, andwhat was given15INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESInfluencers should state the nature ofthe material connection (i.e. freeproducts, monetary compensation,exclusive invite to an event), name thebrand, and list the specific productsthey are promoting. Blanketstatements that are not product andbrand-specific are not transparent forthe viewers.

Don’t:Simply “tag the brand”Effective Disclosure Tips Some influencers only tag their sponsors, some tagbrands with which they have no relationships, andsome do a bit of both. Viewers cannot be sure thatsimply tagging a brand indicates material connection.hihicoffee If there is a material connection between the brandand influencer, it needs to be specifically mentioned.Example Highlights Tagging a brand may not be viewed and interpreted byviewers as clearly indicative of a material connectionbetween the band and the influencer. Even if no monetary exchange occurred, an exchangeof goods, services, or experiences may constitute asmaterial connection.16INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINESxyz creations

Do:Disclosuresshould beclearlycommunicatedContext matters. Viewers should beable to see or hear the disclosure incontext with the brand mention.Some mediums may require bothvisual and audio disclosures.Disclosures should be written, said,and/or displayed somewhere it canbe easily read, heard, or seen. For example, Facebook/Instagram videosoften play without sound, so a visualdisclosure would be required. ForInstagram photo posts, inclusion in thecaption should suffice. If a creator uses a lot of hashtags/mentions at the end their content, thenthe disclosure should always be prior tothose hashtags/mentions. If disclosures are buried in hashtag lists,or are displayed in overlays too small orfaint, they could be considered hidden.17INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Don’t:Ambiguous HashtagsEffective Disclosure Tips The use of ambiguous phrases or hashtags does notmake it clear to the viewer that there is a materialconnection. Examples include using: #Ambassador,#Partner, #Spon, #PR, #Promo, #PRHaul, #Brand,#Collab. If disclosures are buried in hashtag lists, or aredisplayed in overlays that are too small or faint, theycould be considered hidden.Example Highlights Usage of hashtags like “#collab” are not clearindicators that this was a sponsored post or theproduct was gifted. The disclosure attempt was also buried in a list ofhashtags, which is not be considered a clear indicatorfor viewers.18INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Don’t:Fabricated HashtagsEffective Disclosure Tips Knowing that influencers received access to a privateevent, or free experience—sometimes including traveland accommodations—could affect how much weightreaders give to influencers’ thoughts about the product. Inclusions like “thanks to X brand for inviting me” or“I’m at X event with X brand" would suffice. A brand that were to create their own disclosurehashtag needs to ensure that the material connectionis obvious.Example Highlights Influencers should be transparent with their viewersabout free trips they are gifted from brands. Fabricated disclosure hashtags from brands may notbe clear about the nature of the material connection.19INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Don’t:Ambiguous PhrasesEffective Disclosure Tips When creating disclosures (notices, hashtags, etc.), it isimportant to use clear and commonly understoodlanguage. Influencers and brands should not assume thatviewers will understand industry-specific terms andjargon. Disclosures should be simple, straightforward, andeasy to understand. Treating “Thank Company Name” as mandatorydisclosures is not advisable. A “thank you” to a companyor a brand does not necessarily communicate that theendorser got something for free or that they were givensomething in exchange for an endorsement. Simple disclosures like “Company X gave me this productto try . . .”, “XYZ Resort paid for my trip”, or “Thanks toXYZ Resort for the free trip” are just as accurate as“sponsored by XYZ Resort” and will usually be effective.Example Highlights Usage of “a week away with @travelagogo” does notmake the material connection clear to the followers ofthis influencer. The “#partner” disclosure attempt does not clear thatthere is a material connection between the influencerand brand.20INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Do:Disclosuresshould be writtenwith unambiguouslanguageInfluencers and brands should not makeany assumptions that the viewer willinterpret language as a disclosure of amaterial connection.Treating “Thank Company Name” as aneffective disclosure is not advisable. A“thank you” to a company or a brand doesnot necessarily communicate that theendorser received something for free orthat they were given something inexchange for an endorsement.The person posting could just be thankinga company or brand for providing a greatproduct or service. But “Thanks XYZ forthe free product” or “Thanks XYZ for thegift of ABC product” would be goodenough – if that is all you got from XYZ.21INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Do I Need to Disclose?ExampleDoI need toDisclose?GuidanceGifted items:“I was gifted an item from a brand for me to try out, butthere wasn’t an agreement or obligation for me to postabout the brand or product.”Viewers may assess the review differently if they knew the product was gifted ordiscounted, so it is advised that disclosure be included.Employees:“I’m an employee at company XYZ, a clothing retailer, andam excited to be at XYZ’s concert, so I post about it.”It is a relevant material connection that the person posting is an XYZ employee,even if s/he does not post specifically about the retailer’s products. The employeeis promoting XYZ’s brand and a disclosure is required, such as #XYZemployee.Tagging brands:“I received products from a brand, so I’ll tag the brand in myInstagram post and assume my audience knows it was givento me.”Some influencers only tag their sponsors, some tag brands with which they haveno relationship, and some do a bit of both.Experiences/Events:“I got invited to a private event by a brand to see some oftheir new products.”Knowing that influencers received access to a private event, or free experience—sometimes including travel and accommodations—could affect how much weightreaders give to influencers’ thoughts about the product.If there is a material connection between the brand and influencer, it needs to bespecifically mentioned.Inclusions like ‘thanks to X brand for inviting me’ or ‘I’m at X event with X brand’would suffice.Non-contractual brand mentions:“I’m doing a photoshoot with a brand and want to show myaudience a sneak peek of me on set with the brand.”If the influencer is working in a material relationship with the brand and createscontent, even if it was not the contractually obligated post, they are obligated todisclose.Paid, but genuine endorsements:“I’m getting free products from the brand but I REALLY likethem and would post about them even if I wasn’t paid.”The viewer has the right to know that there is a material connection between thebrand and the influencer, even if the influencer genuinely loves and endorses thebrand.22INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Do I Need to Disclose?ExampleDoI need toDisclose?GuidanceReplies or Direct Messages to a “follower”:”One of my followers asks me questions about the brand Ijust posted about. Do I need to include disclosures in myreply?”When responding to someone’s questions about a specific endorsement via email,text, or direct message, that person should already have seen the disclosure onthe post—thus, a disclosure is not necessary (this is context dependent).Testimonials with no material connection:“I didn’t receive any product, compensation, or experiencefrom the brand, but I want to endorse a product.”If no material connection exists between a brand and the influencer, no disclosureis needed.Code Exception:“I’m a professional athlete with a high-profile partnership witha brand. My audience and the public knows about myambassadorship, do I need to disclose every mention?”When the material connection is one that viewers reasonably expect to exist dueto widespread exposure in other media, such as when a celebrity endorses aproduct or service, then a disclosure may not be necessary. It depends on whetherhis/her followers understand that mentions about products are paid endorsements.This can be difficult to determine, so when in doubt, spell it out.Informative Blast to Influencers:“I received information about an upcoming event, withnothing else included in the package (i.e. no swag, notickets). If I go to the event and post about it, is there amaterial connection that requires disclosure?”A brand can give an influencer a gift. If the nature of the gift is clear, and there isno endorsement, then no additional disclosure would be required if it is a pure gift.Gifted Product but no Endorsement:“I was surprised by a gifted snowboard and posted a video ofme receiving it from the brand.”A brand can give an influencer a gift. If the nature of the gift is clear, and there isno endorsement, then no additional disclosure would be required if it is a pure gift.Posting beyond contractual obligations:’“What if I post beyond the contract range, do I need todisclose every mention.”The viewer has the right to know that there is a material connection between thebrand and the influencer, even if the influencer genuinely loves and endorses thebrand.23INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Affiliate andRefer-a-Friend Marketing24INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINE

Affiliate MarketingThe same legal and self-regulatory principles apply to affiliatemarketing as to other forms of advertising.This means thatconsumers should understand through clear and conspicuousdisclosures when there is a material relationship between the personposting the content and the brand. It is material, for example, if: A third party paid to curate or be on a list of recommendedproducts; or If the person who posts a link receives compensation (orsomething else of value) for each click through to a link provided;or If the person who posts a link receives compensation (orsomething else of value) for products purchased at the linkprovided.Sample disclosure might be: “Thanks to [brand X] for sponsoring this list.” “I receive compensation for each click.” “I receive a percentage back from each product sold on thefollowing site.”Writing or saying “thanks” on its own would not be a sufficientdisclosure.25INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Refer-a-friendWhen asking a consumer to make a post on behalf of a brand, thereader of that post should understand if the consumer receivedsomething of value. In other words, if the consumer will get adiscount for posting, or a discount for each new customer who signsup using that consumer’s code, the reader should understand this. Itis material to know that the consumer chose to post in order to getsomething in return, and not just because of their love of the product.The text to be posted by the consumer could include: “I’ll get 1 off future purchases for each person who signs up.” “If you sign up using my code, I get a 5 credit.” “When I post this, I’m saving 5 off my bill” “Woohoo! For posting this, I get one contest entry.”Depending on the content of the post, it may also be appropriate toinclude #ad. When in doubt, spell it out.26INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

Specific Media ChannelDisclosure Examples27INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINE

TikTokBest Practices for Disclosing PaidCollaborations Disclosure should appear in the caption as part of themain message and it should not be buried amongsthashtags The brand with the material connection should beclearly indicated. Embed the disclosure in video content to ensurethe disclosure is maintained across platforms.Example Highlights 28Disclosures are made in the main message and notburied in the comments or buried amongst hashtags.INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

YouTubeBest Practices: YouTube Disclosures Disclosure should appear at the beginning of the video andbe verbally mentioned or displayed visually in the videoitself (within the first 30 seconds). Disclosure should also be included in the video description. Having multiple disclosures throughout the video is mosteffective. Disclosures should indicate that a brand paid for acollaboration and helped shaped the content (i.e. Thankyou to X for sponsoring and collaborating with me on thisvideo). Do not just rely on platform disclosures like “PaidPromotion”, include your own disclosures.Example Highlights Disclosures are made through both audio (in the first 30seconds) and visual cues (above the fold, in thedescription) in both natural language and an explicit callout in the description.29INFLUENCER MARKETING STEERING COMMITTEE - DISCLOSURE GUIDELINES

YouTubeBest Practices: YouTube Disclosures Disclosure should appear at the beginning of the video andbe verbally mentioned or displayed visually in the videoitself (within the first 30 seconds). Disclosure should also be included in the video descriptio

marketing on any social media channel. With rapidly evolving technology and marketing trends, it is . The Competition Bureau also published a detailed guide for influencer marketing in The Deceptive Marketing Practices Digest - Volume 4, available here: . (or network marketing) A marketing strategy whereby one party receives a commission .

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