Australia: Brand owners: monitoring your social media engagement - what, when, and how often?

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 platforms.

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 include:

• 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 page
• Permissions management: allowing only users of a particular age (eg 18+) or geographic location (eg Australia) to view a brand page
• Automated software to remove inappropriate comments, or language filters preventing profanities from being posted to the page.

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.

Take away

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 communications.

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.