FDA: No Unsubstantiated Claims, Even on Social Media

In case some wondered, FDA guidelines apply on social media as well and liking a post from one of your followers promoting unsubstantiated claims is an endorsement of those claims.

In December 2012, the FDA sent a warning letter to Amarc Enterprises regarding two websites. This letter has garnered attention because it references Facebook. The FDA details a variety of serious concerns over the way Amarc is marketing their vitamins, in particular their websites have numerous testimonials that are unsupported by clinical data.

For example, “PolyMVA helped save my life. I began a regimen of PolyMVA… After 3 months, the Stage 2 cancer was down to Stage 1.” These vitamins have not been approved by the FDA and are being improperly marketed as drugs. Similar claims were made for pets using the products and the FDA notes that this is also a violation.

Here is what the warning letter says about Facebook: “We also note claims made on your Facebook account accessible at: https://www.facebook.com/poly.mva, which includes a link to your website at www.polymva.com. The following are examples of the claims: In a March 10, 2011 post which was ‘liked’ by ‘Poly Mva’:

‘PolyMVA has done wonders for me. I take it intravenously 2x a week and it has helped me tremendously. It enabled me to keep cancer at bay without the use of chemo and radiation… Thank you AMARC’”

The product’s Facebook page has been taken down, but it appears that the claim was posted to the wall. Not only was the claim left on the wall, it was “liked” by the page administrator which would be a clear endorsement of the claim. The letter also mentions a blog post on the Amarc site that makes claims that are unsupported by scientific data.

Interestingly, their other Facebook page is still live and posting things like this: “THE BINDING OF PALLADIUM, A RARE TRACE MINERAL, WITH ALPHA LIPOIC ACID, A POWERFUL ANTIOXIDANT, DRAMATICALLY INCREASES NUTRIENT ABSORPTION AT THE CELLULAR LEVEL AND THROUGHOUT THE BODY – A BREAKTHROUGH THAT DISTINGUISHES POLY-MVA® FROM ANY OTHER SUPPLEMENT!”

I posted a link to the FDA warning letter on their wall and asked for a response. They replied, “Discussions with the FDA are ongoing and the issues raised are being addressed. AMARC is committed to our products and working with health agencies in complying with any applicable rules and regulations. This is somewhat of a normal review in the industry. Thank you for the inquiry and we will continue to support our clients and our products.”

Follow existing guidelines
It’s clear that these websites, the Facebook page and blog provided no clinical data to support any of their claims. This warning letter isn’t really about Facebook or blogs, but about following existing guidelines. The FDA is very clear on labeling and how companies can promote their products. Companies that continue to follow this guidance (on websites, Facebook and blogs) should be fine

Original article

March 1, 2013

Local Marketing Not So Local

According to the CMO Council and Balihoo, brands still struggle with local marketing. Between keeping control over the brand, compliance with corporate directives and the necessity to adapt their effort to local markets only 7% consider their local marketing effective.

Driving customers into store locations is an essential step in the path to purchase, and local advertising is one of the best ways to reach consumers “on the ground.” A February 2013 report by the CMO Council and Balihoofound that local marketing is increasingly happening at the digital level, with the greatest percentage of respondents (27%) reporting that increasing digital investment was the biggest change in their local marketing strategy in the past year. But the study also found that brands are at very different stages in terms of their integration and execution of local marketing.

Just over one-third of those surveyed thought their local capabilities were growing, while 15% of marketers reported struggling or underperforming in their local efforts. Only 7% considered themselves highly evolved in their local outreach.

As brands make a greater push into local marketing, one of the major difficulties they face is executing at the regional level while keeping a corporate focus and quality control on local efforts.

Half of US brand marketers surveyed managed local sales and engagement efforts at the corporate level. In addition, one-third reported a combination of corporate-level monitoring of local efforts, along with franchise and outside network management. To develop local marketing strategy, three out of five marketers said that the CMO or corporate marketing team set local priorities.

Communicating the message of the brand at all levels remains a top priority: 81% cited uniformity of the brands’ values and promises as a goal for the year, and 64% wanted to eliminate customer confusion that conflicting execution caused. This suggests that brand consistency will continue to be more important than incorporating local-level insights and ideas into marketing efforts.

February 25, 2013

Two-thirds increasing spending on paid social media ads

Advertisers’ appetites for paid advertising on social media sites shows no sign of abating in 2013. According to a study conducted for digital brand measurement provider Vizu by Digiday, 64% of US advertisers planned to increase their paid social media ad budgets this year, with just 2% saying they intended to spend less money in 2013 than they did in 2012 on paid social ads.

Most of those increasing their spending on ads on social sites planned to do so by 10% or less. But a significant number were making even larger investments: 26% of respondents reported planning to increase their social media ad spending by 11% or more.

Seven in 10 respondents said they would spend between 1% and 10% of their online budget on social ads, suggesting that for most it is a present, but not a dominant part of the marketing mix. For 13% of respondents, however, it plays a larger role: This group spends 21% or more of their online budgets on paid social media advertising.

Overall, eMarketer estimates that US advertisers will spend $4.1 billion on paid social media ads this year, rising to $5 billion in 2014.

Social Interactions Affect Brand Perception

If brands want to improve their customer perception, having a well-rounded social communications practice that serves both as a marketing outlet and as a place for consumers to solve service issues will help.

In a new study, J.D. Power and Associates measured consumer experience working with companies through their social platform for both marketing (such as receiving a coupon or some other offer through a social channel) and service (such as answering questions about a product or service or solving specific problems) needs.

The study was based on the responses of more than 23,000 consumers and covered 100 brands in six industries: airlines, auto, banking, credit card, telecom and utility. The bottom line: very few companies doing both marketing and service particularly well.

“Hardly any companies are doing equally well on social marketing and social servicing,” Jacqueline Anderson, director of social media and text analytics at J.D. Power, tells Marketing Daily. The discrepancy, she says, has a negative impact on brand perception.

The study found a correlation between a company’s overall social communications and a consumer’s likelihood to purchase and overall perception of the company. Among highly satisfied consumers (those with satisfaction scores of 951 or higher on a 1,000-point scale), 87% said their online interaction with the company “positively impacted” their likelihood of purchase from that company. Meanwhile, 10% of consumers with low satisfaction scores (less than 500) said their experiences with a company’s social communications “negatively impacted” their likelihood of purchase.

According to the study, nearly a third of consumers ages 30-49 and 38% of those over 50 interact with companies via social marketing (compared with only 23% of consumers 18-29). However, 43% of the younger demographic use the channels for social media interactions, while only 18% of those over 50 do.

Understanding exactly which consumers are using social media channels to what end will go a long way in helping companies improve their overall communications, Anderson says. Companies will have to evaluate how consumers are using their social media channels and then develop a strategy to address those patterns. This may require some of them to reorganize.

“It’s kind of a failure to understand why consumers are reaching out,” Anderson says. “Many companies are still organized around servicing on one side and marketing on the other.”

Among the industries evaluated, the auto industry is the only one that performs particularly well when it comes to marketing and servicing via social media. The wireless industry scores well when it comes to social servicing interactions, while utilities perform well in social marketing.

February 20, 2013February 20, 2013

Would You Pay to Promote Your Friends’ Posts?

Facebook thinks so, now you can pay to promote your friends’posts to more people, even without their permission

Until natural language processing improves, only humans can tell what’s important. So Facebook today starts rolling out the option to pay to promote a friend’s posts and get them seen by more people. This will help critical posts bubble to the top of the feed, and let Facebook earn some money, too. The feature respects privacy controls, but could still make you look like a self-important prick.

Facebook began testing the ability to promote your own posts in May 2012 and rolled the feature out to the U.S. in October. See, your average Facebook post only gets seen by about 16 percent of your friends because they aren’t online soon after you post, or you never interact with them on Facebook. Promoted Posts artificially boost your posts so they appear in the news feed to people Facebook wouldn’t have shown them to.

The option has enraged some people, making them feel like they’re being extorted to communicate with their friends. When it first came out, I said Facebook was recklessly endangering the meritocracy of the news feed, which until then only rewarded posts that got the most Likes, comments, shares, and clicks.

But there are real uses for Promoted Posts. If you’re raising money for a good cause, looking for an apartment, or have a big announcement for your company, paying to force it into more people’s news feeds can actually be really valuable, and worth the $7 or so. The price varies by geographic area and how many people it could reach.

Now you can do the same for friends’ posts, or at least you’ll be able to soon. A gradual global roll-out for the feature is starting now, and it’s only available to people with fewer than 5,000 total friends and subscribers.

When you see one you think deserves more attention, you can click the drop-down arrow next to a post to sponsor it, and it will reach a larger percentage of the original audience of the post. That means promoting a friend’s post won’t violate their privacy settings. If the post was set to only show up for their friends, your payment will just make it show up to more of their friends. If their post is publicly visible, your promotion could appear to your friends, too.

Facebook explains “If your friend is running a marathon for charity and has posted that information publicly, you can help that friend by promoting their post to all of your friends. Or if your friend is renting their apartment out and she tells her friends on Facebook, you can share the post with the people you and your friend have in common so that it shows up higher in the news feed and more people notice it.”

One issue, though, is that you don’t need a friend’s permission to promote their posts. And depending on what they said, the extra eyeballs might not always be appreciated.

A friend could jokingly promote an embarrassing photo of me, or my status about something bad happening to me. If I post that I wrote an article or am selling something, a friend might innocently think they’re helping by promoting the update. But when people see the “promoted” tag on my self-serving post and realize money was traded for their attention, they might think I’m tooting my own horn a little too loudly.

Facebook will have to keep an eye on this one. If people use it for evil, or people unwittingly end up looking like a loudmouth used car salesmen in cheap plaid polyester suits that reek of even cheaper cologne, then it may want to give authors the option to prevent promotions.

Source

January 30, 2013

Companies’ Approach to Advertising on Social Media

Since the arrival of social media platforms, companies have tried to figure out how to best use them to get their messages to consumers, often with mixed results. Some brands have embraced the notion that social platforms like Twitter allow constant interaction, for better or worse, with their customers.

Others have turned away from some strains of social media, as General Motors did last spring when it stopped advertising on Facebook while raising questions about the return on its investment. The move had a ripple effect in the advertising world, with many brands questioning whether the costs of being on social media were worth it.

A new report issued Tuesday by Nielsen and Vizu, a research company owned by Nielsen, shows that brands think they might be turning a corner, specifically when it comes to paying for their use of social media.The report examined the opinions about social media marketing among more than 500 digital media professionals — including brand marketers, media agencies and advertisers — from September to October 2012.

The study found that that

89% of advertisers continued to use free social media products. Nielsen did not release the names of specific social media platforms mentioned by the respondents, but they are likely to include Facebook and Pinterest, as well as Twitter.
75% of the companies surveyed said they were also spending more for social media content, which could include paying bloggers to write posts about a product or using third-party technology to push videos on to the Web in the hope that they become viral.
70% of the advertisers surveyed said they dedicated up to 10 percent of their budget to paid social media advertising, while 13 percent dedicated more than 21 percent of their budget. Those numbers are expected to increase in 2013.

The results come as companies like Twitter and Facebook are making more diverse advertising options available to brands. Last year, Twitter announced a number of advertising and media initiatives, including a survey product that enables marketers to ask Twitter users a handful of multiple-choice questions. Facebook began testing a new advertising mechanism using a technology called real-time bidding, which allows advertisers to place bids on ad space at specific times.

“Advertisers are starting to look at social media as an integrated part of their advertising strategy,” said Jeff Smith, the senior vice president of product leadership for advertising effectiveness at Nielsen.

January 22, 2013

Responding to Negative Online Comments

12 basic principles for handling difficult questions, comments and statements on the social web. These apply to communications, marketing and customer service issues as much as they do HR and other activities.

Move fast. The longer you take to respond to comments, the more you risk appearing unresponsive, uncaring or, worse, secretive. According to NM Incite (pdf), users of Facebook pages expect to be responded to within 24 hours and Twitter users within 2 hours. In social media, it often pays more to be quick than 100% accurate.

Be accurate. Despite the pressure on speed, try to be as factual as possible – angry customers and bloggers love to highlight, question and poke holes in wooly or cagey responses. Make sure to double-check the facts with your sources and it you’re not confident about the answer, at the very least acknowledge the question, comment or statement, express concern and say you are looking into it. This can help buy you more time to find the appropriate solution.

Be flexible. Don’t assume that either the complaint is 100% genuine (consider carefully its motivation) or that you are 100% correct in your response. If you don’t have the full facts, say so publicly and communicate updates thereafter regularly. Appear anxious to help, as opposed to desperate to please. Backing yourself into a rhetorical corner can prove awkward when you have to extricate yourself publicly.

Be transparent. Admit if you have made a mistake. Denials, evasions insincere apologies as a means of quietening a community are often quickly spotted by the community and may simply inflame the issue. And while the tactic of trying to take a conversation offline can help diffuse difficult situations by buying you more time to assess the situation and/or find a solution, it can also be seen by the customer as a sign of weakness or withdrawal and lampooned as such.

Be sincere. If the complaint is genuine, apologize sincerely and with humility and in language appropriate to the audience. And yet an apology will mean nothing unless the problem is resolved in a reasonable manner. Sharing what you as an organization have learned through the experience is also a good way of demonstrating that your empathy is genuine.

Be human. As The Cluetrain Manifesto pointed out, ‘conversations among human beings sound human’, and are ‘conducted in a human voice’ that is ‘typically open, natural and uncontrived’. Look to use language that is accessible, engaging and empathetic while remaining at core professional and objective. Avoid jargon and respond direct to the individual or group using their actual names. ‘Dear valued customer’ doesn’t wash it with customers increasingly expecting personal attention.

Be focused. Not all customers are equal, and while social media is leveling the playing field, some – the 1% – are most active in the community. You need to identify your top influencers, make sure to understand their interests, requirements and behaviors, and make sure your PR, marketing and customer service teams understand when and how to interact with them. This is not to say you should ignore the rest of the community which, clearly, must not be allowed to feel unwanted or ignored, but be aware that complaints from highly socially engaged customers, bloggers and other influencers may impact not just the community itself but can also make waves beyond it.

Follow-up. Once you have acknowledged the issue and responded, find ways to engage direct with the customer in question on an ongoing basis. Encouraging deeper discussion on the topic will show you are willing to listen and learn, and help make them feel like you care. Equally, walking away once you have responded can make it appear as if the customer is no longer a priority.

Add value. Following up also provides you with additional opportunities to add value to conversations and hence deepen relationships and re-build trust. Look to be helpful by providing options rather than just a single solution, or be seen to go the extra mile by pointing people to useful or relevant information. People will notice – and may comment on the fact – that you are bending over backwards to help them.

Take control. Negative comments on your community should be actively managed – it is after all your channel. Proactively rebut statements that are demonstrably untrue or misleading and, above all, don’t run away from your page in challenging times as it will only make your detractors appear as victors. Ensure discussions remain within the parameters you have set in your Community Guidelines and enforce your terms regarding offensive posts, the sharing of confidential or personal information about company executives or other members of the community, third party advertising, repeat/verbatim comments etc. And remember that it is within your rights to ban members who consistently flout the rules, though you may want to explain why you are doing it both to the individual and to the community as a whole.

Avoid fights. Don’t antagonize your audience or get into online arguments: as Nestle discovered to its cost in the wake of Greenpeace’s palm oil campaign, David usually wins against Goliath in the court of online public opinion. If the situation is volatile, step back and wait for the right opportunity to engage with the customer in question, meantime work closely with the relevant internal stakeholders – often Sales, Public Relations and Legal – to develop a reasonable solution. Appearing thin-skinned will only make you appear weak and vulnerable.

Don’t censor. Nothing conveys a failure to listen and understand better than censoring or removing criticism from your official online communities or elsewhere. Realize that critical voices are a price of entry to the social web, and that deleting or demanding changes to negative posts can provide detractors with a powerful rhetorical weapon. Rather, always try to maintain the high ground, be seen to be responsive and listening and deploy a strong legal approach only as the final option: deleting content or threatening bloggers may simply result in the so-called ‘Streisand effect’ as complaints escalate and go viral.

It is essential that the teams managing official channels as well as interactions with third party online communities understand these principles and are properly trained in the art and science of handling negative opinion.