It all started when a complaint was lodged with the Advertising Standards Bureau (ASB) in relation to the official Smirnoff Vodka Facebook page.
User-generated content was reported to be of an obscene, sexist and racist nature, accompanied by depictions of irresponsible drinking. The ASB ruled that Facebook pages managed by brands are a form of advertising, and therefore brands are responsible for the content written by fans on their Facebook pages. The ACCC joined the debate this week, setting the expectation that brands take down inappropriate Facebook comments within 24 hours.
While newsworthy and currently causing a lot of discussion within the industry, the ruling actually won’t have huge ramifications for brands.
Essentially, best practice in social now just became law. Most brands should be able to keep calm and carry on with what they’re already doing.
The one significant change that brands need to consider is that they now have liability under consumer protection laws for misleading conduct. Even if it’s through user-generated-content. So where in the past, inappropriate fan comments were annoying, now they have the potential to do serious damage to a brand’s business.
What Brands Need To Do:
The ASB ruling is effective now so brands should take immediate action to change or update their Facebook marketing activities.
1. All owned Facebook pages should leverage the in-built comment filter and moderation block list. Every profanity filter should be set to 'strong', and community managers should also be encouraged to add their own key words to the moderation block list. Use the filter tools that are available to automatically reduce the number of ‘inappropriate’ comments.
2. Ensure you have robust community management in place, which includes checking the page regularly for new comments. Not all brands need 24 hour community management, but should be checked regularly to ensure the integrity of comments being left on the page are up to general advertising standards, as well as meeting consumer protection laws for misleading conduct. The ACCC’s advice that brands should remove inaccurate or inappropriate user generated comments within a day or less means Community Managers should be on the alert on weekends as well as ‘business’ hours.
3. Ensure that all owned and official Facebook pages have community guidelines or house rules in place. Amongst other things, these should make it clear that rude, offensive interactions and spam won’t be tolerated. A process should also be developed for such material to be removed.
With the ASB ruling, accuracy is now up there with the most important checks to make on your site. Guidelines around posting factual comments will let community managers hide, remove or correct any inaccurate information posted by fans.
Dealing with inappropriate/inaccurate comments
If fans swear, bully, are racist, defamatory or inaccurate, or say something inappropriate in a wall post, be ready to respond with pre-approved comments explaining why you’re hiding or deleting the comment, or in repeat/extreme cases, blocking the person from the Page.
Provided you are upfront about your reasons for deleting or blocking people, your community should be understanding of the need to do this at times.
So, what next?
Regardless of future developments on this over the coming weeks, these principles should be applied to all brand communities and social engagements to ensure good results. It’s a challenging and complex area. Documentation should be prepared and procedures followed. Knowing what you’re doing and having the necessary experience in this space could not only save a brand significant time and resource but could also save a brand from damage and financial penalties.
Simon Small
Executive Planning Director
Visual Jazz Isobar
Andy Cronin
Lead Community Manager
Visual Jazz Isobar