Following decisions of the Advertising Standards Board regarding
the use of social media for advertising, the Australian Association
of National Advertisers (AANA) has issued a Best
Practice Guideline on Responsible Marketing Communications in the
Digital Space to assist brand owners advertising on digital
Digital marketing communications were confirmed to constitute
'advertising' in recent determinations by the Advertising
Standards Board. We wrote about those determinations in a previous
article – click
here to view.
Significantly, a brand owner can be held responsible for
user-generated content (UGC) on social media
platforms over which it has reasonable control. However, until
recently, little guidance had been given as to what content should
be monitored and how often monitoring should take place. The
Guideline is designed to assist brand owners in applying the
AANA's Code of Ethics.
In its Guideline, some of the AANA's recommendations
Established "house rules" which define and let users
know what is acceptable UGC and the consequences of breaching those
rules (eg deletion of UGC or the blocking of the user)
Email notifications when a user posts or comments on a brand
Permissions management: allowing only users of a particular age
(eg 18+) or geographic location (eg Australia) to view a brand
Automated software to remove inappropriate comments, or
language filters preventing profanities from being posted to the
The Guideline recommends that when a brand owner moderates UGC
on digital platforms, it should consider community expectations and
levels of activity on that platform. Moderation may take the form
of removing, correcting or responding to UGC.
'Best practice' moderation needs to be tailored to the
specific brand, business and marketing channel, but as a guide
'best practice' should involve moderation immediately after
posting and for at least two hours following the post. At other
times, the AANA recommends moderation at least once a business day,
with moderation increasing during periods of increased consumer
engagement (which may occur over weekends or public holidays). This
is consistent with recommendations given by the ACCC for monitoring
social media for false, misleading and deceptive comments (see:
ACCC Information Sheet).
If a brand owner believes UGC offends community standards or is
misleading or deceptive, it should remove the offending post,
upload or comment, but this would not necessarily require it to
remove the entire conversation or brand page.
Social media can be a highly effective advertising tool. Brand
owners and advertisers need to be aware of codes, regulations and
guidelines which will ensure best practice in advertising on
digital and social platforms.
The implementation of a clear social media policy incorporating
the AANA's recommendations will assist in reducing the risk of
complaints from the public, or investigations by the Advertising
Standards Bureau or ACCC into particular marketing
Effective monitoring of UGC will also reduce the risk of a
brand's reputation being damaged by the publication of
misleading, deceptive or offensive content on social media.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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