Looks like the FTC is ready to update the Dot Com Disclosures, and every Internet business owner, affiliate marketer and mobile advertiser should start paying close attention to the process – because the current chatter suggests that the stringent new rules being discussed could radically change the scope of online business.
The topics the FTC appears to be most concerned about are disclosures on mobile offers, social networking platforms and pre-landing pages.
On May 30th, the FTC will hold a public workshop focusing on disclosure rules for mobile marketing. Currently, they’re accepting panelist participant submissions and are requesting opinions on the questions below.
1) Due to the increasing prevalence of mobile devices, how can the proper FTC disclosures fit in the limited space?
2) Geo-location technology is opening up a brave new advertising world. As such, what should be the proper disclosure procedure for sat-enabled ads? For example, when should disclosures be made available to an individual plugged into a geo-location advertising program? Is it when the offer pops up on the person’s mobile device, or is it fine to not require customer notification until they decide to act on the offer (i.e., actually walking into the establishment).
3) For devices that do not have downloading capabilities, is providing users a way to send themselves obligatory disclosures, for future review, a sufficient way to include the necessary disclosures?
4) How should social media and disclosure obligations be married? Are there disclosure considerations that should be weighed with regards to re-tweets, Facebook posts, etc.?
5) What is the best way for clear promotion disclosures to be incorporated into mobile devices with limited display areas?
6) What are the current statistics on mobile phone use? How do people interact with their phones these days?
7) What is the best way to incorporate hyperlinks, jump-links and click-through mechanisms into mobile advertisements? Should a graphical standard be set up to indicate various policy, terms and disclosure requirements?
If you are involved in mobile or online advertising, keep the FTC investigation into digital disclosures on your radar. If you’re involved with Internet marketing and need an attorney to review your online advertising efforts, get in touch.