You’ve probably seen it. A slickly edited video on YouTube in which a young, chatty, and enthusiastic person is inviting us into their lives, telling us about what they do, where they like to eat, where they like to shop, what console games they play and introducing us to their family and friends as they “vlog” about it all.
Vloggers – video bloggers – are seen as relatable, trustworthy and honest to their viewers because they come across just like you and me, with an attainable lifestyle. Some of the vloggers are so popular they have amassed a multi-million following of loyal subscribers. There are Scottish vloggers with videos on everything from make-up tutorials to comedy clips and cycling stunts across Scotland.
Vloggers start off making videos in their spare time because they enjoy it. But precisely because of their relatability to the public, it’s a no-brainer that some advertisers have been approaching them to engage in a commercial relationship to endorse a product or service or to sponsor a video.
The Advertising Standards Authority (ASA) doesn’t have a problem with this. There is nothing wrong with responsible advertising and research shows consumers are happy to engage with it.
All we ask is that where the brand controls the content and the vlogger has been paid (monetary or a freebie) to promote a product or service on their own channel, they make this clear to viewers.
Viewers should not be left in the position of being misled into believing their favourite vlogger absolutely loves a product when it turns out they have been paid to endorse it.
Last week, the US Federal Trade Commission ruled that retailer Lord & Taylor fell foul of guidelines on native advertising. The company gave a free dress and a financial payment to 50 “influencers” in return for posting a picture of the dress and promoting the company on their Instagram accounts. Lord & Taylor reviewed and pre-approved each post. None of the participants disclosed payment. That was wrong.
Although this case involved the medium of Instagram rather than vlogging, it shows how seriously the issue is taken across the pond.
We take it seriously in the UK too, with the ASA having reason to tackle the same issue. For example, we upheld a complaint against Mondelez UK Ltd when they paid vloggers to promote Oreos on their behalf.
Our sister body, the Committee of Advertising Practice, published guidance last year which makes clear when and how vloggers should inform viewers when content is advertising rather than their normal editorial pieces.
For example, if the content is controlled by the marketer, not the vlogger, and is written in exchange for payment (including free items) then it is an advertisement feature and must be labelled as such (rule 2.4).
Another example is where most of the vlog is editorial material that contains independent, non-paid-for opinion, with a specific section dedicated to the promotion of a product.
There is no need for a label or statement in the title of the vlog that it is an ad when the surrounding material is independent editorial.
However, the situation needs to be clear onscreen when watching the vlog, once the ad starts – via text stating “ad”, “ad feature”, the vlogger holding up a sign, incorporating the brand’s logo or simply explaining that they’ve been paid to talk about the product.
We are not trying to be killjoys regarding what is a hugely popular recent phenomenon, however, where there are complaints, the ASA is prepared to act. No-one should be put off by FTC and ASA rulings if they stick to the rules.
Shabnum Mustapha is Scottish affairs lead at the Advertising Standards Authority, www.asa.org.uk