PRSA Commentary — FTC 'Dot Com Disclosure' Guidelines

August 10, 2011

VIA ELECTRONIC SUBMISSION

Federal Trade Commission
Office of the Secretary
600 Pennsylvania Avenue, NW
Room H-113 (Annex I)
Washington, DC 20580

RE: Comments of the Public Relations Society of America (PRSA)
to Proposed Revisions to Dot Com Disclosures (FTC Matter No. P114506)

Members of the Commission:

The Public Relations Society of America (PRSA) is pleased to submit comments and supporting materials
in response to a request by the Federal Trade Commission (FTC) for public comments on proposed
revisions to the FTC’s “Dot Com Disclosure” guidelines (the “Guidelines”). PRSA appreciates the
opportunity to comment on what will surely become valuable revised guidelines for online and digital
advertising, marketing and communications professionals, not to mention the value these revised
guidelines will provide for online consumer protections.

PRSA is the world’s largest organization of public relations and communications professionals. Our
members are directly affected by FTC rules and regulations governing the use of online and digital
marketing claims in public relations, marketing and advertising materials, as part of integrated
communications and marketing programs executed on behalf of clients and employers.

Many of our members are regularly involved — or will be involved — in the production and
dissemination of online and digital marketing communications, messaging and materials that are read,
viewed or listened to by consumers.

PRSA is a 501c(6) professional organization representing more than 21,000 professionals, as well as
10,000 student members of our ancillary Public Relations Student Society of America (PRSSA), who
practice public relations in every state and territory of the United States and abroad. PRSA is responsible
for representing, educating, setting standards of excellence and best practices, providing certification and
upholding principles of ethics for its members, and more broadly, the $5.2 billion U.S. public relations
industry.

Members of PRSA include: independent practitioners; small business owners; employees of government
agencies; corporations; academic institutions; law firms and professional services practices; public
relations firms of all sizes and practice specialties; and nonprofit institutions of every size and description.
PRSA membership also includes professionals who engage public relations as part of a comprehensive
mix of marketing communications and advertising strategies to achieve client objectives.

The Society operates under the direction of a board of directors elected each year by the general
membership, with a chair and chief executive officer overseeing direction of the Board and of the general
Society. Guidance for the organization in fulfilling its mission — to advance the standards of the public
relations profession and professionals through education, innovation and adherence to a strong code of

33 Maiden Lane, 11th Fl. . New York, NY 10038-5150 . Tel: 212-460-1400 . Fax: 212-995-0757 . www.prsa.org

ethical behavior — stems from the organization’s published bylaws and its industry-leading code of
ethics.

We thank the FTC for the opportunity to present our views. If you have any questions or would like to
discuss these issues further, please contact Keith Trivitt, associate director of public relations, at (212)
460-1495 or keith.trivitt@prsa.org.

Respectfully submitted,

Rosanna M. Fiske, APR Deborah A. Silverman, Ph.D., APR
Chair and CEO Chair, Board of Ethics & Professional Standards
Public Relations Society of America Public Relations Society of America

William M. Murray, CAE Keith Trivitt
President and Chief Operating Officer Associate Director of Public Relations
Public Relations Society of America Public Relations Society of America

Appendix:

• Full commentary of Public Relations Society of America, pp 1–10.
• Appendix One: PRSA Member Code of Ethics, pp 11–16.
• Appendix Two: Professional Standards Advisory PS–8 (October 2008): Deceptive Online
Practices and Misrepresentation of Organizations and Visuals, pp 17–18.
• Appendix Three: PRSA commentary for 2010 WOMMA Ethics Code review, p 19.
• Appendix Four: PRSA op-ed in MediaPost (Jan. 14, 2011), “Raising Disclosure’s Digital Profile,
pp 20–21.
• Appendix Five: PRSA letter to the editor of The New York Times (July 5, 2011) re increasing
digital disclosure awareness and transparency among businesses victimized by cyberattacks, p 22.
• Appendix Six: PRSA op-ed in PRMoment.com (Feb. 1, 2011), “U.S. and U.K. Must Maintain
Professional Standards When Using New Technologies,” pp 23–24.
• Appendix Seven: PRSA letter to the editor of Technology Review (May/June 2011) re
WikiLeaks’ impact on transparent corporate communications, p 25.
• Appendix Eight: PRSA op-ed in All Things WOM (Jan. 25, 2011), “Digital Disclosure — Modern
Challenge for Modern Marketers,” pp 26–27.

33 Maiden Lane, 11th Fl. . New York, NY 10038-5150 . Tel: 212-460-1400 . Fax: 212-995-0757 . www.prsa.org

Response to Request for Comment
Federal Trade Commission

FTC Matter No. P114506
Proposed Updates to “Dot Com Disclosure” Guidelines
Comments of the Public Relations Society of America (PRSA)

A. Comment Summary
This document provides commentary on behalf of the 32,000 members of the Public Relations Society of
America and the broader U.S. public relations industry. It is based on substantial background on the most
current professional standards for ethical communications, as established by PRSA.

You will find that PRSA is a strong advocate for ethical and transparent communications and marketing
practices, especially as that pertains to online communications channels in which consumers now perform
a plurality, if not a majority, of their purchasing and decision-making activities. In fact, PRSA has made
digital disclosure a cornerstone of its national and international advocacy initiatives this year. We have
had published commentary, op-eds and letters to the editor on the need for incorporating more stringent
disclosure practices in digital marketing and communications in The Guardian newspaper, MediaPost,
PRMoment.com, CMO.com, Technology Review, and the Word of Mouth Marketing Agency (WOMMA)
blog, All Things WOM.

We encourage the Commission to give careful consideration to the ethical guidelines and practice
standards for transparent communications and marketing practices, as established by PRSA and
WOMMA. The guidelines under consideration should encourage broader application of principles already
in place with PRSA membership, and we encourage that. (The U.S. Census Bureau notes1 that there are
approximately 200,000 public relations practitioners in the United States, as of 2006. Of those,
approximately 22,000 are represented by PRSA, making it the world’s largest professional association
representing public relations and communications professionals, but by no means a majority of
practitioners.) As noted throughout this document, we also support more specificity in the FTC’s
guidelines to ensure there can be no misunderstanding about standards of digital disclosure by businesses.

PRSA commends the FTC staff for their initiative to revise the “Dot Com Disclosures” guidelines. The
original guidance document has provided invaluable guidance and insight into how marketers and
communicators can legally and ethically advertise and communicate online with consumers. However,
like all communications channels, online advertising and marketing is a constantly evolving space. The
2000 guidelines, therefore, are in need of significant revisions that take into account the drastic changes
that have occurred in technology and media, both for businesses and consumers.

This change has helped build a robust online advertising and marketing industry, but one that is becoming
increasingly fraught with confusion concerning ethical disclosure in online advertising and marketing
communications. There are a number of key issues on which marketers do not know whether their online
disclosures would be acceptable according to FTC guidelines. We strongly believe that the time has come
for a robust update and modernization of the FTC’s original online disclosure guidelines, to better reflect
the current and future realities and challenges that marketers and consumers face.

In addition to soliciting and reviewing public comments, we strongly urge the Commission to hold a

1 Statistics of U.S. Businesses: 2006: NAICS 54182 – Public relations agencies, United States. It is published at
http://www.census.gov/epcd/susb/2006/us/US54182.HTM

Comment of Public Relations Society of America to FTC Matter No. P114506 Page 1

public workshop this year in order to solicit a full public exchange of views on these issues. PRSA
suggests the FTC invite key industry and consumer trade groups and other interested parties to this
workshop to hear a variety of suggestions for how the FTC can continue to ensure consumers digital
rights are protected, while also aiding businesses in realistically and responsibly meeting the challenge of
digital disclosure.

PRSA believes strongly in consumer protections. Part of our mission is to help advance the free flow of
accurate and transparent information that helps inform society and aid in the public’s knowledge. We urge
the Commission to maintain the foundational principle in the updated Guidelines — as was the case in the
original guidance document. Specifically, that the same consumer protection laws apply to marketers
whether they operate online or offline. Above all, protection of consumers’ rights is paramount.

To be clear, we believe the public relations profession in the United States is a responsible steward in
upholding and respecting consumer protections and ensuring that the public is fully informed of pertinent
information, resources and data, including, but not limited to, disclosure within digital communications
and marketing. Our 22,000 professional members all sign a Member Code of Ethics2 and agree to abide
by a set of ethical standards. Foremost among those ethical tenets is the free flow of information.

Therefore, we do not believe it is necessary for the FTC to further restrict how businesses communicate,
advertise and market online. Rather, we urge the Commission to provide significant clarification and
education as to how modern communications channels and technologies available to businesses should be
used. Furthermore, we request that the FTC help marketers better understand and judge where challenges
may lie within those mediums in which the Commission has purview.

PRSA also believes that disclosure of relationships, motivation, compensation and other pertinent factors
should be the basis of all forms of marketing and communications, including emerging practices like
social media and online contests. Ethical marketing and communications require that marketers
reasonably inform consumers of the motivations and intent of use behind the messaging they receive
throughout the process, no matter the medium used.

Following are some of the steps PRSA regularly takes to keep its members informed about the ethical
communications and marketing standards that come into play in the day-to-day course of their business
activities:

• PRSA routinely publishes ethics and professional standards advisories for its members, as it did
in late-2008, via PS-83, “Deceptive Online Practices and Misrepresentation of Organizations and
Visuals”.
• PRSA states its positions in opinion pieces, letters to the editor, position statements, blog posts
and commentary, along with participating in interviews with both trade media and general
consumer media at every opportunity.
• PRSA annually bestows awards for best practices in the development of some of the industry’s
top environmental marketing and public relations campaigns. These awards for best practices
have as one of their core principles the practice of ethical and transparent messaging and
marketing claims.
• PRSA routinely offers professional development courses on specific tactics, such as the
development of messaging online, for mobile dissemination and across social media, and where

2 PRSA Member Code of Ethics, which is signed voluntarily by each member of the Society. It is published at
http://bit.ly/9VZZCQ and is attached to this document as Appendix One. The current code has been in place since 2000. It
replaced a previous code that had been last revised in 1988.
3 Professional Standards Advisory PS-8 (October 2008): Deceptive Online Practices and Misrepresentation of Organizations and
Visuals. It is published at http://bit.ly/nqLj5s and is attached to this document as Appendix Two.


the transparency requirements are also discussed and reinforced.
• PRSA members are able to earn accreditation, designated by APR (Accreditation in Public
Relations) or APR+M (Accreditation in Public Relations + Military) after their names, through
written and oral testing. Individuals who go through the APR or APR+M Accreditation process
must be well versed in ethical professional practices , including proper disclosure of the sources
and sponsorship of materials sent to the media and disseminated to the public.

PRSA’s Code of Ethics contains important guidelines for ethical and transparent online communications
and marketing practices:

• Professional Values
o Advocacy. Public relations practitioners serve the public interest by acting as responsible
advocates for those we represent. We provide a voice in the marketplace of ideas, facts
and viewpoints to aid informed public debate.
o Honesty. Public relations practitioners adhere to the highest standards of accuracy and
truth in advancing the interests of those we represent and in communicating with the
public.
o Expertise. Public relations practitioners acquire and responsibly use specialized
knowledge and experience. We advance the profession through continued professional
development, research and education. We build mutual understanding, credibility and
relationships among a wide array of institutions and audiences.
o Independence. Public relations practitioners provide objective counsel to those we
represent. We are accountable for our actions.
o Loyalty. Public relations practitioners are faithful to those we represent, while honoring
our obligation to serve the public interest.
o Fairness. Public relations practitioners deal fairly with clients, employers, competitors,
peers, vendors, the media and the general public. We respect all opinions and support the
right of free expression.

• Code Provisions:
o Free Flow of Information. Protecting and advancing the free flow of accurate and
truthful information is essential to serving the public interest and contributing to informed
decision making in a democratic society.
o Disclosure of Information. This provisions states that a member shall be honest and
accurate in all communication. Act promptly to correct erroneous communication for
which the member is responsible. Investigate the truthfulness and accuracy of
information released on behalf of those represented. Reveal the sponsors for causes and
interests represented. Disclose financial interest such as stock ownership of the client
organization, past client work or affiliation. Avoid deceptive practices. And disclose or
help expose deceptive practices where possible
o Conflicts of Interest. Avoiding real, potential or perceived conflicts of interest builds the
trust of clients, employers and the publics.
o Enhancing the Profession. Public relations professionals work constantly to strengthen
the public's trust in the profession. Investigate the truthfulness and accuracy of
information released on behalf of those represented.

In response to the Commission’s request for comments on updating the “Dot Com Disclosure” guidelines,
PRSA would like to offer the following views:


I. Realities and Challenges of Digital Disclosure

Among public relations and communications professionals who regularly engage in digital
communications and marketing and/or social media efforts, one of the chief concerns and issues is
discerning when, where and how frequently disclosure must be made. With the proliferation of
communications channels, such as Twitter, that thrive, and in many cases, require, short brand messaging,
communicators are frequently facing challenges over how often to include disclosure within their digital
brand messaging and marketing, and where that disclosure should appear.

For example: If Brand X is writing a Tweet promoting an upcoming contest found on its website, must
the company place a disclosure link within that Tweet, or would it be appropriate for the disclosure link to
be found on the Web page that the Tweet links out to?

PRSA urges the FTC to provide guidance on how retweets and other redistribution and dissemination of
brand messaging across social networks affect digital-disclosure requirements. Many social networks
have a character or word-count limit that often makes it difficult for disclosure links or messaging to be
included within the main context of the communications or advertisement. In the case of a retweet or
Facebook “Like,” we ask that Commission to clarify whether a brand should make it possible for
consumers to retransmit the disclosure link and/or disclosure messaging every time that message is
disseminated. We suggest the FTC consider whether there are other channels by which businesses can
ensure digital disclosure is still provided, such as through the use of approved third-party apps (e.g.,
TwitLonger, CMP.ly and Deck.ly) that allow businesses to include extra communications within Tweeted
messages, thereby, improving the chances that consumers will pass along a business’ digital disclosure
messaging when redistributing the original message.

II. Social Media Contests

A frequently used component of public relations campaigns are social media contests. While presenting
numerous opportunities to brands and marketers, PRSA recognizes that the proliferation of social media
contests presents issues for consumers, particularly regarding the protection of their rights to be fully
informed of the motivations and interests of businesses engaging in and providing for a contest.

In commentary submitted in January 20114 to the Word of Mouth Marketing Association, as part of its
2011 Ethics Code review, PRSA advocated the following regarding the importance of disclosure within
social media contests:

There needs to be disclosure — by the marketer and by the person engaged in that contest —
within every single message, blog post, tweet, etc. mentioning that contest. The breadth of social
networks and how far they reach means that marketers now capture consumers’ interests at
different times and through different lenses.

Where practical, social media contests should provide a link to a clear and simple Web page
noting all of the uses for the contest, the information submitted as part of the contest and to whom
that information will be given to and for what purposes.

A simple feature that would allow for all messaging and communications within a social media
contest to contain the necessary disclosure, and within space/character limitations, can be found
in a free service like CMP.ly, which provides a tiny URL link back to a comprehensive disclosure
page relevant to that specific contest.

4 PRSA Commentary for 2010 WOMMA Ethics Code Review. It is published at http://bit.ly/gjIGQw and is attached to this
document as Appendix Three.


We suggest the Commission consider specific aspects of this commentary, as well as that of WOMMA’s
Ethics Code5, in its revised Dot Com Disclosure guidelines.

III. Further Implications of the “Blogger Rules”

PRSA has been a vocal advocate of the FTC’s revised Guides Concerning the Use of Endorsements and
Testimonials in Advertising (the “Blogger Rules”). Representing our 32,000 members, as well as the
broader public relations profession in the United States, we have spoken out frequently6 about the need
for public relations professionals to abide by these guidelines and to do so transparently and earnestly.

For PRSA, the “Blogger Rules” resonate with a familiar echo. Transparency principles in the PRSA Code
of Ethics parallel both the new guidelines and align with its Professional Standards Advisory PS-97
condemning “pay-for-play” practices.

We have also guided our members and the public relations profession through real-world examples and
case studies of issues they should avoid in order to not run afoul of the Guides. Writing on the PRSA
executive blog, PRSAY, Sept. 2, 20108, in reference to the FTC’s 2010 settlement with Reverb
Communications over fake product reviews, former PRSA Chair and CEO Gary McCormick, APR,
Fellow PRSA, said: “The PRSA Code of Ethics, to which all PRSA members pledge, calls for truthful,
accurate and transparent communications. What could possibly be truthful, accurate or transparent about
posting positive reviews of a client’s product, without disclosing that you’ve been paid to do so?

“The same ethics that apply to off-line communications also must be applied to social media
conversations and other forms of online communications. Consumers have a right to know that the
information they read online is accurate and truthful. They also have a right to know if a product
“reviewer” has been paid to offer a positive opinion of a product or service.”

Despite this advocacy on the FTC’s behalf to convey the value of ethical communications and marketing
strategies and tactics when engaging third-party endorsers and testimonials, our members have concerns
regarding whether the revised Dot Com Disclosure guidelines will further impact the FTC’s “Blogger
Rules”; if so, to what extent overlap may exist between the two sets of guidelines.

We note that in the case of the “Blogger Rules,” disclosure of a company sponsoring a blog post, by way
of example, has little to no difference than the disclosure required by the FTC when a company places an
ad on a website. In either case, advertising or endorsement (whether implicit or explicit) space is being
purchased and a company’s messaging is being disseminated. However, as it stands now, two sets of
guidelines govern these communications, each with somewhat overlapping goals and regulations.

In the interest of clarity and simplicity, we urge the FTC to consider folding its “Blogger Rules” into the
broader Dot Com Disclosure guidelines. As online marketing and communications activities continue to
blend with other digital marketing initiatives, such as online testimonials and product reviews, it is
imperative that the FTC’s revised Dot Com Disclosure document serve as a comprehensive guidebook for
a variety of marketing communications initiatives.

5 WOMMA Ethics Code. It is published at http://womma.org/ethics/code/intro/.
6 “$250K Reasons to Pay Attention to the FTC’s ‘Blogger Rules’,” PRSAY blog, March 25, 2011. It is published at
http://bit.ly/eDEYGk.
7 Professional Standards Advisory PS-9: Pay-for-Play (October 2008). It is published at http://bit.ly/q6aVhY.
8 “Unethical Product Reviews Have No Place in Public Relations,” PRSAY blog, Sept. 2, 2010. It is published at
http://bit.ly/9r1XA7.


IV. Clarity of Disclosure

Despite the proliferation of social-media communications and its accompanying movement toward more
succinct messaging, we have observed that in recent years, corporate disclosures on websites have
become longer and more complex. Rather than helping consumers understand what they are about to
purchase or agree to, the disclosures often bewilder consumers or leave them exasperated and unwilling to
read important information about how their information and data may be used by a business.

We believe in clarity of communications. Foremost among our belief is that companies should be
transparent in their communications and marketing and should aid in the decision-making process for
consumers, rather than adding to the confusion that can accompany a purchase decision.

Many online shopping sites have an area where consumers must agree to the terms of service/agreement
before purchase. However, the terms of service/agreement are lengthy and the average on-line shopper
will not take the time to fully read the document.

We suggest the FTC identify what information from the terms of service/agreement must be displayed on
the website, in clear and concise language. Also, we urge the Commission to recommend that businesses
place a link on the purchase page that will take the consumer to the full disclosure document. This
document should be no more than one page and should contain all vital information in a transparent and
clear manner. The goal of online brand disclosures should be more than just a catch-all for the business to
ensure it has legally met its obligations. Online disclosure documents should help to properly inform
consumers about how their personal information and data is being used, where it may be used and what
value the company could derive from it.

In short, online disclosures should act as more of an informant for consumers, rather than a deterrent
toward obtaining knowledge.

V. Mobile Communications and Marketing

With smartphones having overtaken feature phones in America9 and 72.5 million Americans10 using
smartphones, marketers are increasingly reaching consumers via their mobile phone, rather than more
traditional forms of online advertising, such as display ads. PRSA believes that the mobile phone is on the
cusp of becoming the most powerful communications and marketing medium in the world. Many of our
members, as well as the more than 200,000 public relations professionals in the United States, work
within the mobile public relations and marketing space, on behalf of clients or their employers.

Pursuant to our commitment to protecting consumer rights and ensuring transparent communications and
marketing are provided, we want to stress to the FTC our members’ commitment, as well as that of the
entire public relations profession, to responsible communications and marketing within the mobile space.

Regarding the original Dot Com Disclosures recommendation that a disclosure appear on the same screen
as a claim, we share the FTC’s continuing desire to make disclosures easy to find and read, particularly in
the mobile space. However, we seek additional guidance from the Commission as to how marketers can
meet this recommendation given that smartphone screens present a very limited space upon which
consumers can view a brand’s message.

We also request the FTC consider when and where a disclosure should be placed within mobile

9 “Smartphones to Overtake Feature Phones in U.S. by 2011,” Nielsen Wire, March 26, 2010. It is published at
http://bit.ly/b9MvdG.
10 “comScore Reports March 2011 U.S. Mobile Subscriber Market Share,” comScore.com, May 6, 2011. It is published at
http://bit.ly/l1dTrC.


communications and marketing so that a business’ marketing efforts do not become overly cumbersome
by the need to include a disclosure in a space that may not be natural to those reading it on a smartphone,
or is limited due to space constraints. The innovation that will help generate $3.3 billion in mobile
advertising revenue in 201111, more than double the industry’s 2010 revenue figures, has been possible
because marketers have experimented in ways that may not have been possible had regulation been
implemented sooner. We recognize that communicators and marketers must act responsibly when
communicating in this evolving medium. We believe that with prudent and relevant revised Guidelines,
our members and the public relations profession will ably and earnestly meet this responsibility.

VI. General Disclosure Issues

As the world’s largest professional organization of public relations and communications professionals,
PRSA spends a great deal of time advising and educating our members on proper and ethical disclosure
standards in traditional, digital and social-media communications and marketing. The core of our
advisement comes from PRSA’s Member Code of Ethics, which has as one of its primary tenets the
advancement and protection of the free flow of accurate and truthful information that is essential to
serving the public interest and contributing to informed decision making in a democratic society.

We also issue periodic updates to the PRSA Code of Ethics, based on evolving technology and changing
social and professional mores. Among those was our 2008 update focused on deceptive online practices
and misrepresentation of organizations online. With the perspective we have gained from this
background, we offer the following suggestions for FTC staff to consider when revising the guidance
document:

A. Character and Text Limitations

The proliferation of social media, mobile computing and new technologies has produced dozens, if not
hundreds, of new communications and marketing channels. Each has its own unique communication
style, cadence and limitations. Chief among those is Twitter. The 140-character limit of Twitter messages
has been a boon to creative and succinct marketing communications, but it has introduced unique
challenges for communicators and marketers wishing to express their brands’ full messaging while also
staying within FTC guidelines for disclosure.

Because of this, numerous services, such as TwitLonger, have sprouted up to allow for more detailed
communications across Twitter. However, we have observed some recurring scenarios for which we think
additional staff guidance would be beneficial for businesses.

First, if a disclosure cannot be made within the original messaging because of space limitations, marketers
may refer consumers to a disclosure found on a subsequent longer form of the original communications,
such as a brand Facebook page, company blog or via a third-party app, such as TwitLonger and Deck.ly.
This would allow individuals and businesses to disseminate Twitter messages longer than 140 characters,
through which a disclosure link could be prominently placed.

The latter example presents some obvious challenges. We ask the FTC to clarify the following potential
issues we believe could cause marketers to run afoul of any guidelines:

• Must a link to the disclosure come within the original message or is it acceptable for that link to
be placed in the long-form message, so long as the consumer is able to access the full disclosure?
• Should marketers allow character space for consumers to include the disclosure link within

11 “Mobile Advertising Revenue to Double This Year on Back of Improved ROI: Gartner,” Mobile Marketer, June 17, 2011. It is
published at http://bit.ly/jmOr1z


retweeted messages?
• What is the Commission’s advice on modified Tweets, in which a consumer can place an “MT”
symbol in front of a business’ Tweet (perfectly acceptable according to established Twitter user
norms), and thus, slightly modify its messaging and/or remove a company’s digital disclosure
link.

Second, the original “Dot Com Disclosures” do not address how to convey required disclosure
information when character or space limitations restrict how much messaging marketers can present to
consumers. The original Guidelines recommend that links to disclosure pages should take consumers
directly to the disclosure. However, given that many brand messages within social media are frequently
altered by consumers upon redistribution of a business’ messaging across their personal social networks,
which may remove or modify the disclosure link and/or disclosure messaging, we request that the
Commission provide clear guidance on where, when and how disclosure links should be displayed.

B. Point of Purchase

The original Dot Com Disclosure document says all online brand disclosures must be communicated
before the point of purchase. However, most disclosures appear on the initial screen before selecting
products to purchase. Therefore, a consumer may have multiple products with various disclosures, but are
only able to view these disclaimers and disclosures once. Regardless of the pathway, online disclosures
should be communicated repeatedly before the point of purchase, for all products. Furthermore, we
suggest the Commission consider a including a recommendation that all disclosures accumulate on the
purchase page for one final review by the customer before any transaction.

C. Frequency of Disclosures

The frequency of disclosure within social media communications is another area we believe needs
modification and revision. In the old Guidelines, it was assumed that consumers were coming directly to a
company Web page, through search or other means, or were viewing an online ad. However, in today’s
socially-connected media environment, consumers are often passive viewers of brand ads and messaging.
We believe this presents a significant challenge to the ethical communicator and marketer. Specifically,
we suggest the FTC provide guidance on how often disclosure must be made in social-media messaging,
given that it is rare a consumer will directly seek out a company’s Twitter feed or Facebook page. Instead,
consumers frequently see this content in passing, or while searching for other content.

D. Drawing Appropriate Attention to Disclosures

We also recommend the Commission provide guidance on how marketers can and should draw attention
to their disclosures. Again, given the velocity of social-media communications, as well as the sheer
number of marketing messages disseminated by brands across a variety of digital communications
channels and social networks, we believe it is becoming increasingly difficult for marketers to ensure
their disclosures are seen and that the intent and purpose are absorbed by consumers. We ask the staff to
provide specific examples of how marketers can develop online content and social-media messaging that
clearly draws attention to the disclosure.

E. Consumer Modification of Online Brand Messaging

As we noted above, it is not uncommon for consumers to modify a business’ digital messaging and
social-media communications, particularly when engaging with a brand within social networks that
restrict a user’s character count (such as Twitter and Facebook).

Because of this, we believe it would be helpful for the Commission to address what responsibility, if any,


marketers have concerning how consumers modify and redistribute brands’ messaging across social
networks, given the issues we previously addressed. More concrete guidance and further examples from
staff illustrating relevant situations that marketers may face in this regard, and how the Commission
advises they meet specific disclosure guidelines, would be useful.

To that end, we recognize the Commission’s challenge of trying to develop online disclosure
recommendations that are both stringent in their purview and flexible enough to allow for continued
innovation from marketers within digital and online advertising, marketing and communications.

F. Prominence

A core component of the original Dot Com Disclosure document is prominence, which addresses
marketer’s responsibility to draw attention to required disclosures. PRSA commends the Commission for
the foresight it displayed in placing this tenet within the original documents. It is one we believe is
essential to ensuring ethical and transparent marketing communications are present online and that
consumers’ best interests are kept intact.

We firmly believe that public relations and communications professionals act responsibly when using
social networks in which they are disseminating messaging that requires a relevant disclosure. However,
they face realistic limits due to certain character limitations and other realities within digital and social
media marketing that imperil their ability to prominently and clearly display a disclosure.

The original staff document — having been written in 2000 when a majority of online advertising was
found on a computer screen and did not come in the form of mobile marketing, and most certainly not
within social networks and other digital mediums — is lacking in scope to appropriately address the many
issues and challenges marketers and communicators face in the digital age when it comes to marketing
within multiple screens while still aiming to meet the FTC’s digital disclosure guidelines.

We noted that the original Guidelines only address physical online ads (e.g., display ads, banners, etc.).
Given the prevalence of these ad forms at the time, this made sense. However, with the proliferation of
social media and social networks, the recommendation, for example, that “size matters,” or that “color
counts,” while certainly still relevant for display and banner ads, has little to no bearing or relevance with
social media marketing and communications.

A specific component of the staff’s original “Prominence” guidance that we would like to bring to the
Commission’s attention is that of “burying” a disclosure. The original disclosure guidelines noted that “a
disclosure that is buried in a long paragraph of unrelated text would not be effective.” We wholeheartedly
agree; however, we have concerns that the FTC’s guidance does not address the numerous digital
communications and social media channels that frequently require very brief messaging from brands,
thus, potentially causing a business to innocuously bury a disclosure.

The original staff disclosure document provides only a brief overview of the need for not burying
disclosures. We suggest that staff broaden the “Prominence” tenet to provide guidance for social-media
messaging and marketing and other forms of digital communications.

G. Labeling of Hyperlinks

The prevalence of URL shorteners and the many custom-branded URL shorteners that media outlets,
companies and even consumers now use has given rise to a hodgepodge of link identifiers. Whereas links
once had a distinctive nomenclature and labeling (e.g., www.PRSA.org, www.nytimes.com,
www.ftc.gov) that clearly delineated their meaning and origin, modern hyperlink usage by consumers and
businesses has taken on an entirely new form, largely predicated by truncated communications that have


developed to fit within character and space limitations of mobile communications, social networks and
society’s general predilection toward succinct communications.

We note that the original Dot Com Disclosures document discusses “label[ing] the [disclosure] hyperlink
appropriately to convey the importance, nature and relevant of the information it leads to.” This is a noble
request, but in modern marketing usage, it has little relevance. Given the fleeting nature of the torrent of
marketing communications that consumers are now subjected to, we suggest the Commission consider
more flexible ways in which businesses can ensure the labeling of their hyperlinks is clear but takes into
account the realities of marketing and communicating to consumers within certain character and space
limitations.

VII. Conclusion

The Public Relations Society of America thanks the FTC for its foresight in recognizing that the
significant technological innovations and change that has occurred in recent years has necessitated
updated guidance to businesses and marketers on how best to apply FTC advertising guidelines to online
activities. We suggest that the FTC continue to pursue and provide more specific recommendations for
marketers12, especially as they seek to use more nuanced marketing communications channels. We also
suggest that the FTC commence a public workshop to further explore the topic, and we look forward to
continuing our engagement with Commission staff on these important issues.

12Although not directly related to the issues presented in the request for comments surrounding “Dot Com Disclosures,” we
suggest that FTC staff consider providing marketers and businesses with guidance on two other important and related issues: (1)
whether the act of a business ‘Liking’ or retweeting another business’ page or post on Facebook and/or Twitter constitutes an
endorsement by that business for the other business’ products or services and/or constitutes advertising by that business on behalf
of the other company; and (2) whether disclosures under the Endorsement Guides are needed when a business retweets another
tweet (i.e., whether the act of retweeting constitutes an endorsement.


APPENDIX ONE

PRSA Member Code of Ethics

Preamble

Public Relations Society of America Member Code of Ethics 2000

• Professional Values
• Principles of Conduct
• Commitment and Compliance

This Code applies to PRSA members. The Code is designed to be a useful guide for PRSA members as
they carry out their ethical responsibilities. This document is designed to anticipate and accommodate, by
precedent, ethical challenges that may arise. The scenarios outlined in the Code provision are actual
examples of misconduct. More will be added as experience with the Code occurs.

The Public Relations Society of America (PRSA) is committed to ethical practices. The level of public
trust PRSA members seek, as we serve the public good, means we have taken on a special obligation to
operate ethically.

The value of member reputation depends upon the ethical conduct of everyone affiliated with the Public
Relations Society of America. Each of us sets an example for each other — as well as other professionals
— by our pursuit of excellence with powerful standards of performance, professionalism, and ethical
conduct.

Emphasis on enforcement of the Code has been eliminated. But, the PRSA Board of Directors retains the
right to bar from membership or expel from the Society any individual who has been or is sanctioned by a
government agency or convicted in a court of law of an action that is in violation of this Code.

Ethical practice is the most important obligation of a PRSA member. We view the Member Code of
Ethics as a model for other professions, organizations, and professionals.

PRSA Member Statement of Professional Values

This statement presents the core values of PRSA members and, more broadly, of the public relations
profession. These values provide the foundation for the Member Code of Ethics and set the industry
standard for the professional practice of public relations. These values are the fundamental beliefs that
guide our behaviors and decision-making process. We believe our professional values are vital to the
integrity of the profession as a whole.

ADVOCACY

We serve the public interest by acting as responsible advocates for those we represent. We provide a
voice in the marketplace of ideas, facts, and viewpoints to aid informed public debate.


HONESTY

We adhere to the highest standards of accuracy and truth in advancing the interests of those we represent
and in communicating with the public.

EXPERTISE

We acquire and responsibly use specialized knowledge and experience. We advance the profession
through continued professional development, research, and education. We build mutual understanding,
credibility, and relationships among a wide array of institutions and audiences.

INDEPENDENCE

We provide objective counsel to those we represent. We are accountable for our actions.

LOYALTY

We are faithful to those we represent, while honoring our obligation to serve the public interest.

FAIRNESS

We deal fairly with clients, employers, competitors, peers, vendors, the media, and the general public. We
respect all opinions and support the right of free expression.

PRSA Code Provisions

FREE FLOW OF INFORMATION
Core Principle

Protecting and advancing the free flow of accurate and truthful information is essential to serving the
public interest and contributing to informed decision making in a democratic society.

Intent

• To maintain the integrity of relationships with the media, government officials, and the public.
• To aid informed decision-making.

Guidelines

A member shall:

• Preserve the integrity of the process of communication.
• Be honest and accurate in all communications.
• Act promptly to correct erroneous communications for which the practitioner is responsible.
• Preserve the free flow of unprejudiced information when giving or receiving gifts by ensuring
that gifts are nominal, legal, and infrequent.


Examples of Improper Conduct under this Provision:

• A member representing a ski manufacturer gives a pair of expensive racing skis to a sports
magazine columnist, to influence the columnist to write favorable articles about the product.
• A member entertains a government official beyond legal limits and/or in violation of government
reporting requirements.

COMPETITION

Core Principle

Promoting healthy and fair competition among professionals preserves an ethical climate while fostering
a robust business environment.

Intent

• To promote respect and fair competition among public relations professionals.
• To serve the public interest by providing the widest choice of practitioner options.

Guidelines

A member shall:

• Follow ethical hiring practices designed to respect free and open competition without deliberately
undermining a competitor.
• Preserve intellectual property rights in the marketplace.

Examples of Improper Conduct under This Provision:

• A member employed by “client organization" shares helpful information with a counseling firm
that is competing with others for the organization's business.
• A member spreads malicious and unfounded rumors about a competitor in order to alienate the
competitor's clients and employees in a ploy to recruit people and business.

DISCLOSURE OF INFORMATION

Core Principle

Open communication fosters informed decision making in a democratic society.

Intent

• To build trust with the public by revealing all information needed for responsible decision
making.

Guidelines

A member shall:

• Be honest and accurate in all communications.


• Act promptly to correct erroneous communications for which the member is responsible.
• Investigate the truthfulness and accuracy of information released on behalf of those represented.
• Reveal the sponsors for causes and interests represented.
• Disclose financial interest (such as stock ownership) in a client's organization.
• Avoid deceptive practices.

Examples of Improper Conduct under this Provision:

• Front groups: A member implements "grass roots" campaigns or letter-writing campaigns to
legislators on behalf of undisclosed interest groups.
• Lying by omission: A practitioner for a corporation knowingly fails to release financial
information, giving a misleading impression of the corporation's performance.
• A member discovers inaccurate information disseminated via a Web site or media kit and does
not correct the information.
• A member deceives the public by employing people to pose as volunteers to speak at public
hearings and participate in "grass roots" campaigns.

SAFEGUARDING CONFIDENCES

Core Principle

Client trust requires appropriate protection of confidential and private information.

Intent

• To protect the privacy rights of clients, organizations, and individuals by safeguarding
confidential information.

Guidelines

A member shall:

• Safeguard the confidences and privacy rights of present, former, and prospective clients and
employees.
• Protect privileged, confidential, or insider information gained from a client or organization.
• Immediately advise an appropriate authority if a member discovers that confidential information
is being divulged by an employee of a client company or organization.


• A member changes jobs, takes confidential information, and uses that information in the new
position to the detriment of the former employer.
• A member intentionally leaks proprietary information to the detriment of some other party.


CONFLICTS OF INTEREST

Core Principle

Avoiding real, potential or perceived conflicts of interest builds the trust of clients, employers, and the
publics.

Intent

• To earn trust and mutual respect with clients or employers.
• To build trust with the public by avoiding or ending situations that put one's personal or
professional interests in conflict with society's interests.

Guidelines

A member shall:

• Act in the best interests of the client or employer, even subordinating the member's personal
interests.
• Avoid actions and circumstances that may appear to compromise good business judgment or
create a conflict between personal and professional interests.
• Disclose promptly any existing or potential conflict of interest to affected clients or organizations.
• Encourage clients and customers to determine if a conflict exists after notifying all affected
parties.

Examples of Improper Conduct under This Provision

• The member fails to disclose that he or she has a strong financial interest in a client's chief
competitor.
• The member represents a "competitor company" or a "conflicting interest" without informing a
prospective client.

ENHANCING THE PROFESSION

Core Principle

Public relations professionals work constantly to strengthen the public's trust in the profession.

Intent

• To build respect and credibility with the public for the profession of public relations.
• To improve, adapt and expand professional practices.

Guidelines A member shall:

• Acknowledge that there is an obligation to protect and enhance the profession.
• Keep informed and educated about practices in the profession to ensure ethical conduct.
• Actively pursue personal professional development.
• Decline representation of clients or organizations that urge or require actions contrary to this
Code.


• Accurately define what public relations activities can accomplish.
• Counsel subordinates in proper ethical decision making.
• Require that subordinates adhere to the ethical requirements of the Code.
• Report ethical violations, whether committed by PRSA members or not, to the appropriate
authority.


• A PRSA member declares publicly that a product the client sells is safe, without disclosing
evidence to the contrary.
• A member initially assigns some questionable client work to a non-member practitioner to avoid
the ethical obligation of PRSA membership.

PRSA Member Code of Ethics Pledge

I pledge:

To conduct myself professionally, with truth, accuracy, fairness, and responsibility to the public; To
improve my individual competence and advance the knowledge and proficiency of the profession through
continuing research and education; And to adhere to the articles of the Member Code of Ethics 2000 for
the practice of public relations as adopted by the governing Assembly of the Public Relations Society of
America.

I understand and accept that there is a consequence for misconduct, up to and including membership
revocation.

And, I understand that those who have been or are sanctioned by a government agency or convicted in a
court of law of an action that is in violation of this Code may be barred from membership or expelled
from the Society.

________________________________________
Signature

________________________________________
Date


APPENDIX TWO

Professional Standards Advisory PS-8 (October 2008) — Deceptive Online Practices and
Misrepresentation of Organizations and Individuals

TO: Members of the Public Relations Society of America

FROM: PRSA Board of Directors — PRSA Board of Ethics and Professional Standards

RE: Professional Standards Advisory PS-8 (October 2008) — Deceptive Online Practices and
Misrepresentation of Organizations and Individuals

All PRSA members pledge adherence to the Society's Member Code of Ethics. As issues arise relating to
the practice of public relations, the Board of Ethics and Professional Standards (BEPS) is charged with
providing guidance on such issues within the framework of the Code provisions. The PRSA Board of
Directors then announces these guidelines through this series of professional standards advisories. The
PRSA Member Code of Ethics may be found online at www.prsa.org .

ISSUE: Misrepresentation by organizations and individuals using blogs, viral marketing, and anonymous
Internet postings with undisclosed sponsorships and/or deceptive or misleading identities or descriptions
of goals, causes, tactics, sponsors or participants. (Note: The term “Flog” has been coined to describe a
“fake blog,” where an organization or its representative creates an online forum that appears to be from a
private citizen expressing personal opinion or experiences, when, in fact, it is being maintained for hire
with an undisclosed agenda.)

BACKGROUND: A number of Web sites and deceptive social networking postings have surfaced on
behalf of issues, candidates running for public office and products blindly sponsored by individuals,
industries and organizations. PRSA members are reminded that open communication is essential for
informed decision-making in a democratic society.

RELEVANT SECTIONS OF THE PRSA CODE: At least three Code provisions and three
professional values relate to this issue. They are:

Code Provisions

• Free Flow of Information. Protecting and advancing the free flow of accurate and truthful
information is essential to serving the public interest and contributing to informed decision
making in a democratic society.
• Disclosure of Information. This provisions states that a member shall be honest and accurate in
all communication. Act promptly to correct erroneous communication for which the member is
responsible. Investigate the truthfulness and accuracy of information released on behalf of those
represented. Reveal the sponsors for causes and interests represented. Disclose financial interest
such as stock ownership of the client organization, past client work or affiliation. Avoid deceptive
practices. And disclose or help expose deceptive practices where possible
• Conflicts of Interest. Avoiding real, potential or perceived conflicts of interest builds the trust of
clients, employers and the publics.
• Enhancing the Profession. Public relations professionals work constantly to strengthen the
public's trust in the profession. Investigate the truthfulness and accuracy of information released
on behalf of those represented.


Professional Values
• Honesty. We adhere to the highest standards of accuracy and truth in advancing the interests of
those we represent and in communicating with the public.
• Fairness. We deal fairly with clients, employers, competitors, peers, vendors, the media and the
general public.
• Advocacy. We serve the public interest by acting as responsible advocates for those we represent.
We provide a voice in the marketplace of ideas, facts and viewpoints to aid informed public
debate.

EXAMPLES OF IMPROPER PRACTICES
• The CEO of a company poses as a stock analyst and makes glowing remarks about her
company’s performance on a popular financial blog and recommends the stock.
• An agency creates a fake identity and uses the identity to post favorable comments about a
client’s social responsibility activities on a number of blogs and social networking sites.
• A member of a political candidate’s staff disguises his identity and posts negative comments
about the opposing candidate on a number of political blog sites.
• A public relations executive at a corporation wants to obtain the phone and text records for a
public relations assistant who she suspects of leaking information to the media, so she pretends to
be that person wanting to check her bill and requests a summary of her calls from her cell phone
provider.
• An agency representative impersonates a client’s online critic and posts favorable comments on a
blog.
• A political campaign staffer sets up some Web pages on a popular social networking site that look
like they were created by the opponent, and the pages misrepresent the opponent’s position on a
number of issues and make inflammatory statements about other candidates.
• A competitor’s staff intentionally enters incorrect or misleading information about their own
products or their competitor’s product on a popular on-line encyclopedia.
• A public relations firm is hired to post favorable comments on Wikipedia about a number of
clients. She poses as a neutral, third-party to post the comments.
• A public relations practitioner, to curry favor with a reporter, allows access to a client’s private
text conversations, email and pre-release web/blog comments.

RECOMMENDED BEST PRACTICE: The use of deceptive identities or misleading descriptions of
goals, causes, tactics, sponsors or participants to further the objectives of any group constitutes improper
conduct under the PRSA
Member Code of Ethics and should be avoided. PRSA members should not engage in or encourage the
practice of misrepresenting organizations and individuals through the use of blogs, viral marketing, social
media and/or anonymous Internet postings.

PRINCIPAL BEPS AUTHOR: Pat Whalen, APR

October 2008
Published at: http://bit.ly/nqLj5s


APPENDIX THREE

PRSA commentary for Word of Mouth Marketing Association (WOMMA)’s 2010 Ethics Code Review
(submitted: Jan. 5, 2011)

PRSA Commentary — WOMMA 2010 Ethics Guide Review

Contests:
Disclosure of relationships, motivation, compensation and other pertinent factors should be the basis of
all forms of marketing and communications, including emerging practices like social media and online
contests. Ethical marketing and communications require that marketers reasonably inform consumers of
the motivations and intent of use behind the messaging they receive throughout the process, no matter the
medium used.

There needs to be disclosure — by the marketer and by the person engaged in that contest — within every
single message, blog post, tweet, etc. mentioning the contest. The breadth of social networks and how far
they reach means that marketers now capture consumers’ interests at different times and through different
lenses.

Where practical, social media contests should provide a link to a clear and simple Web page noting all of
the uses for the contest, the information submitted as part of the contest and to whom that information
will be given to and for what purposes.

A simple feature that would allow for all messaging and communications within a social media contest to
contain the necessary disclosure, and within space/character limitations, can be found in a free service
like CMP.ly, which provides a tiny URL link back to a comprehensive disclosure page relevant to that
specific contest.

Material Connection within Contests:
A material connection does exist between a brand and a blogger (or any participant) when the blogger
writes about and/or discusses his or her contest entry in any format (blog, Tweet, Facebook, LinkedIn,
etc.). This is particularly true if the participant is trying to obtain some type of personal or professional
benefit from the contest and/or from his/her promotion of that contest.

Rosanna Fiske, APR
Chair and CEO
Public Relations Society of America (PRSA)

Published at: http://bit.ly/gjIGQw


APPENDIX FOUR

Raising Disclosure’s Digital Profile
MediaPost
By Rosanna M. Fiske, APR, PRSA Chair and CEO
Published: Jan. 14, 2011

Buzzwords abound in the marketing, public relations and advertising industries. Phrases like
"convergence," "cord-cutting" and "engagement" quickly come to mind. Each captured our attentions,
invaded our Twitter streams and just as often, was trite from the moment it was first uttered.

But one crucial word has often been missing: disclosure.

To earn the public's trust, it's crucial that we provide transparency and truth regarding the motivating
factors of online marketing and social media campaigns, who's running the show and what information is
being collected. Unfortunately, this key word, which is becoming increasingly relevant to the public and
to government regulators, is often absent from the industry's trending topics.

If disclosure isn't on your list of words to tweet, blog or chat about this year, it needs to be because it's
primed to be the next big thing in online marketing and communications. We just may not realize it until
it's too late.

That's because at this very moment -- and for perpetuity -- we have a responsibility to better self-regulate
our practices and ensure consumers are getting the full picture every time they interact online with our
brands.

To be sure, efforts are already underway to raise the profile and importance of disclosure in online
marketing. Last November, the Word of Mouth Marketing Association (WOMMA) examined as part of
its annual ethics code review a key question concerning the level of disclosure within social media
contests.

As chair and CEO of the Public Relations Society of America, I submitted commentary to WOMMA,
which noted: "Disclosure of relationships, motivation, compensation and other pertinent factors should be
the basis of all forms of marketing and communications, including emerging practices like social media
and online contests."

Not exactly a Twitter-friendly comment, but a vital point for marketers to consider as they aim to improve
relationships with consumers, while ensuring the public is fully informed.

WOMMA's effort to help digital marketers navigate the often confusing precepts of digital disclosure is
commendable. So is the discussion that took place around its review process and any ensuing provisions
adopted by the association.

A snapshot of recent online marketing mishaps more clearly illustrates the value of greater disclosure in
online marketing practices:

From cheating allegations in the Pepsi Refresh campaign to concerns over data scraping within online
message boards to the Federal Trade Commission's calls for companies to voluntarily let consumers opt-
out from having their browsing data collected by Web marketers, a view from the outside would likely


show a profession that is incredibly innovative, but struggling to convince people that it has their best
interests in mind.

It doesn't have to be this way. We can and should do more to help the public understand the value of the
information they provide when interacting online with our brands. But we must be willing to give them
the peace of mind they desire and already receive in many offline marketing practices.

With the FTC taking an increasingly refined look into digital marketing and advertising practices, it
behooves all communicators to be on top of this now, before government regulators begin to crack down -
- even more so than they already have.

Disclosure within digital marketing and social media has always been fraught with technical challenges,
concerns over best practices and standards and a bevy of other legitimate (and sometimes, not so
legitimate) concerns. One area that should engender unilateral agreement among marketers, however, is
that now is the time for better self-regulation and a higher degree of disclosure.

In order to keep consumers coming back for more, and to reap the rewards without stringent regulatory
oversight, we must adopt a far more sophisticated and responsible approach to disclosure.

Published at: http://bit.ly/r3SSLE


APPENDIX FIVE

PRSA letter to the editor of The New York Times re increasing digital disclosure awareness and
transparency among businesses victimized by cyberattacks (July 5, 2011)

Letter: Enhancing Online Security
Published: July 5, 2011

To the Editor:

“The Cloud Darkens” (editorial, June 30) rightly advocates for increasing online security, but doesn’t
mention a key component missing from most proposals to thwart cyberattacks: increased disclosure from
hacked companies regarding the impact on customer data.

The revelation that the online document-storage service Dropbox tried to hide a glitch in its network that
allowed any user to log into any account is but one of several examples of companies failing to
adequately disclose vital information about customer data, how it is being used and what steps are being
taken to mitigate the effects of cyberattacks.

The need for greater disclosure is clear: cyberattacks represent one of the greatest challenges facing
modern businesses and are costly to economies and society alike. According to a 2004 report by the
Congressional Research Service, targeted companies suffer an average loss in stock market valuation of
between $50 million and $200 million, with total consumer and business losses estimated at more than
$200 billion a year.

We may never be able to eradicate the pernicious effects of cyberattacks. But we can ensure that the
public is not victimized twice, by pushing for more timely and transparent disclosure from affected
companies. Anything less allows the hackers to win, while the public continues to lose.

ROSANNA M. FISKE
Chairwoman and Chief Executive
Public Relations Society of America
New York, June 30, 2011

Published at: http://nyti.ms/n7Bbh5


APPENDIX SIX

U.S. and U.K. Must Maintain Professional Standards When Using New Technologies
PRMoment.com
Published: Feb. 1, 2011

The US and the UK must ensure we maintain professional standards when using new technologies says
PRSA’s chief executive Rosanna Fiske.

One wouldn’t have necessarily thought this the case, but America’s and the UK’s “special relationship”
apparently extends to how our respective governments regulate commercial speech among bloggers and
marketers.

For the uninitiated (and this may include American readers), the UK’s Office of Fair Trade (OFT)
launched last December its “Handpicked Media” investigation in an effort to uncover the level of
engagement of “handpicked media” of bloggers on a commercial basis. In essence, it’s a form of the
United States Federal Trade Commission’s 2009 ruling of similar note, otherwise known as the “FTC
blogger rules.”

The details of the OFT’s investigation and the implications it may have on the UK public relations and
marketing industries have been thoroughly deliberated. I thought it might be useful, however, to provide a
perspective from America on where public relations stands. More specifically, the work many
professionals, including my colleagues at the Public Relations Society of America (PRSA), are currently
undertaking to implement stronger ethical standards within emerging public relations and marketing
practices.

The global public relations profession has had its ups and downs, no doubt. But one common thread that
has held our work together for generations, and helped us increase our value to businesses and the public,
has been our commitment to upholding ethical standards and best practices. Similarly, our profession
thrives on smartly utilising modern technologies, strategies and tactics to meet our clients’ and
organisations’ goals.

Facebook. Twitter. Foursquare. Quora. The list of new technologies, channels and other dazzling, real-
time communication vehicles goes on and on. But so do the ethical concerns each raises – if we’re not
prudent in our efforts to fully understand the implications of using new channels and technologies, and
their benefits for clients and for serving the public good.

That isn’t to say we should delay our adoption or use of new technologies. Absolutely not.

But it does mean we have a responsibility to ensure the same stringent ethical standards and best practices
guiding our traditional services are infused in work that engages new technologies and techniques.

A fascinating article in the January/February issue of the Columbia Journalism Review brought this into
perspective for me. Author Paul Niwa’s juxtaposition of journalist and author Jacob Riis’ experimentation
in visual storytelling with the entrepreneurial spirit this might engender in 21st-century journalists,
provides an enlightening analysis of the technological challenges and opportunities that have greeted
journalists for centuries. Niwa notes that Riis was fascinated by the new medium of photojournalism, yet
employed caution when using what at the time was a new tool.


Caution isn’t always bad; in fact, it can give us invaluable time to reflect on our goals and objectives. But
at a certain point, we must progress. That evolution should include a modernisation of ethical standards
and best practices in order to meet today’s pressing business and societal concerns.

While we may not be measured by our proficiency with technology, the collective work of public
relations professionals will most certainly be examined by how well we uphold our responsibility to the
public and the business community to communicate in a responsible and ethical manner, no matter the
medium or technology we employ.

Rosanna Fiske, APR, is chair and chief executive officer of the Public Relations Society of America
(PRSA). She is also program director of the Global Strategic Communications master’s program in the
School of Journalism and Mass Communication at Florida International University in Miami.

Published at: http://bit.ly/gs2AnW


APPENDIX SEVEN

PRSA letter to the editor of Technology Review re WikiLeaks’ impact on transparent corporate
communications (May/June 2011)

Letters and Comments: The Role of WikiLeaks
Published: May/June 2011

Thank you for your truly spot-on column examining the impact of WikiLeaks on society's concept of
secrecy and transparency ("Is WikiLeaks a Good Thing?" March/April 2011). Like you, I often find
myself conflicted about the value of WikiLeaks. I tend to eschew overt calls for full disclosure from
organizations — whether by government leaders, executives, or individuals pushing a cause—because my
first inclination is to uphold the right to privacy.

However, instances in the past year throughout the global business community have begun to change my
mind. And as the associate director of public relations for the Public Relations Society of America, I am
committed to transparency and disclosure in all forms of communication to advance the free flow of
accurate and truthful information, which is vital to democratic societies.

While WikiLeaks may take corporate transparency too far for some, numerous surveys have revealed that
trust in American businesses and government is terribly low. Perhaps it is time to look past the potentially
sinister goals of Julian Assange and WikiLeaks and develop a more earnest commitment to withholding
only information that truly deserves secrecy.

Keith Trivitt
Associate Director of Public Relations
Public Relations Society of America
New York

Published at: http://bit.ly/fowSCf


APPENDIX EIGHT

Digital Disclosure — Modern Challenges for Modern Marketers
All Things WOM
Published: Jan. 25, 2011

The past five years have been a remarkable time for marketers, communicators and public relations
professionals. Twitter, podcasts, blogs, Facebook, et al. (Quora, anyone?) have infused a new and
refreshing vibrancy into our respective professions, making them more relevant to consumers and the
public, and equally valuable to the business community.

But that increased value comes with greater responsibility. More specifically, a responsibility to ensure
that the same ethical standards and best practices developed by WOMMA and PRSA, which are widely
regarded as the benchmarks for their respective professions, are instilled in today’s emerging marketing
practices.

Unfortunately, many times, those ethical benchmarks are missing, or loosely applied, across the digital
side of the marketing and public relations spectrum. And that’s a shame because we have the resources,
collective intelligence and call-to-action from the public, business community and government regulators
to do so much more.

That is one of the reasons why PRSA has advocated for strong ethical standards across all marketing
disciplines for more than 60 years. Like WOMMA, we understand and respect the value that ethical
communications and marketing have toward serving the public good and helping businesses prosper.

But we also understand the time and resource constraints placed on modern communicators. We’re in an
era where incorporating such norms as disclosure isn’t necessarily in “vogue.” It’s a time of rapid-fire
online engagement between brands and consumers, where greater emphasis is often given to reaching the
biggest influencers, rather than how well you connect with and inform your core audiences.

That leaves the ethical marketer stuck in the middle between aiming high with disclosure and other ethical
standards, but possibly feeling constrained by time, resources and client pressures. Not to mention the
increasingly abbreviated space available to actually provide proper disclosure. (Hello, 140 characters!
Actually, make that 120 characters, if you want to get retweeted …)

The corollary is that trust between brands and consumers has been shaped in the eyes of numerous recent
digital marketing mishaps. From cheating allegations in the Pepsi Refresh campaign to concerns over data
scraping within online message boards to a less-than-receptive response from some online ad and
marketing firms to the FTC’s efforts to allow consumers to opt-out of having their browsing data tracked,
a view from the outside would likely show a profession that is incredibly innovative, but struggling to
convince consumers that it has their best interests in mind.

Not all is bleak, however. The 2010 Edelman Trust Barometer found that trust in businesses has stabilized
and is trending upward, going from an all-time low of 36 percent in 2009 to 54 percent in 2010.

And out of the ashes of numerous recent corporate crises has arisen a greater understanding and respect
among executives for the strategic value of ethical WOM and public relations. No longer seen as merely a
series of “one-off” campaigns to build brand awareness and “buzz,” these distinct disciplines now


comprise the pinnacle of a global movement toward developing and sustaining companies that are aligned
with the goals and collective norms of a global society.

All of which makes 2011, I have to believe, the year when we finally find that happy middle ground
between real-world marketing realities and instilling modern ethical standards for modern marketing
practices.

Published at: http://bit.ly/eS7ZSc


PRSA Commentary — FTC 'Dot Com Disclosure' Guidelines

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PRSA Commentary — FTC 'Dot Com Disclosure' Guidelines