A Flow Chart of Disclosure


This may need some tweeking, but it’s a draft at an attempt to understand the disclosure rules in a flow chart manner- let me know what you think- does this help, or simply confuse things further?

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  1. Hey Whit,

    Thanks for all these excellent posts you’ve been sharing about the new FTC rules on disclosure. As a Canadian, I’m watching closely. As a blogger, I’ve always been upfront about the relationships I’ve had with brands when discussing their products and/or services. As a digital strategist, I counsel clients and other online influencers about the importance of disclosure as well.

    If this question has already been asked and/or answered, I apologize but I’d like to know what the FTC rules are for a blogger who writes about a product (product B) that she purchased on her own if she has previously been given another product (product A) from the same company (or agent of that company) in hopes of her writing about product A. Does the blogger have any relationship that needs to be disclosed with respect to product B?


  2. I would say product b is something you bought n your own and reviewed on your own- no disclosure about product A which was not reviewed needed. Now is receiving product A prompted you to go out and buy (and try) product B, maybe that’s worth mentioning… ie. I was sent a sample of X, and as a result, I went out and bought Z- Z is really fantastic! Now readers will question what you thought about X… but strictly speaking, you don’t have to mention A at all. Different transactions altogether.

  3. Whit, thanks again. There seems to be a lot of gray and being from outside the U.S. may present another set of challenges for both agencies and online influencers.

  4. I think the biggest issue if you are doing a blogger outreach campaign and it reaches into the States, would be to make sure the bloggers know that you expect them to disclose any relationship openly, as there is potential liability for advertisers, and that a few quick lines about “please include in any review you might write that you received this product….” will help cover a lot of bases.

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  7. This is great, if used proper flowchart symbols had been used it would have been great.

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