FTC Endorsement FAQ – Our company’s policy says that employees shouldn’t post positive reviews online without disclosing their relationship. Are we liable if an employee posts a review and doesn’t disclose that relationship?

Compliance > Advertising / Marketing Misc. > FTC Endorsement Guidelines
Q:  Our company’s policy says that employees shouldn’t post positive reviews online about our products without clearly disclosing their relationship to the company. All of our employees agree to abide by this policy when they are hired. But we have several thousand people working here and we can’t monitor what they all do on their own computers and other devices when they aren’t at work. Are we liable if an employee posts a review of one of our products, either on our company website or on a social media site and doesn’t disclose that relationship?
 
A:  It wouldn’t be reasonable to expect you to monitor every social media posting by all of your employees. However, you should establish a formal program to remind employees periodically of your policy, especially if the company encourages employees to share their opinions about your products. Also, if you learn that an employee has posted a review on the company’s website or a social media site without adequately disclosing his or her relationship to the company, you should remind them of your company policy and ask them to remove that review or adequately disclose that they’re an employee.
 
 
This FAQ was pulled from the Federal Trade Commission’s website, as of the date of this article.  Additional information may be found here: https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking
 

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