Social Media Tools

Breaking Out of Social Disclosure Jail With CMP.LY

It’s been about 15 months since those crazy kids at the Federal Trade Commission (FTC) passed their new disclosure guidelines to “protect the public” from inappropriately cozy business relationships being companies and bloggers, tweeters, Facebookers and more.

Since then, we’ve been expecting a steady procession of corporate marketers being led to the virtual stockade, given that actual disclosure of business relationships in day-to-day social media reality is spotty at best.

(In fact, while I always disclose here at Convince & Convert if I’m writing about a client, I don’t usually tag my tweets or Facebook statuses as such, which makes me a law breaker. Probably you too.)

So the good news is that the FTC isn’t pummeling brands in the digital octagon like a crazed MMA fighter. But that doesn’t mean they won’t start. Furthermore, a legion of other organizations like the FDA, FINRA, SEC and other governing bodies have passed or are studying social disclosure guidelines.

Thus, like driving on ice while drinking hot coffee and trying to figure out which XM station has the basketball game you want, the best practice is to be extra-cautious with this whole disclosure situation.

Enter CMP.LY

Blogger DisclosureAs has become the standard for URL shortening; Klout has become the standard for influence measuring; and Creative Commons has become the standard for digital copyrights, CMP.LY seeks to become the standard for online disclosure. And they’re well on their way.

CMP.LY easily (if not yet elegantly) solves the main problems facing brands and the bloggers who write or tweet about them, providing a consistent and audited disclosure framework. Here’s how it works:

  1. A company (let’s say my client ExactTarget) works with bloggers to spread coverage of their free new social media research.
  2. ExactTarget identifies bloggers that may be appropriate, possibly using something like BlogDash (which I love).
  3. The company sets ups a disclosure campaign with CMP.LY, stating the terms and conditions of the relationship between ExactTarget and the bloggers. CMP.LY creates a customized disclosure Web page, a shortened URL that leads to it, and a customized campaign ID code.
  4. ExactTarget approaches the targeted bloggers and asks them to participate. For bloggers that agree, the company sends them a care package that includes a printed copy of the research, a Starbuck’s gift card, and a collection of company T-shirts and other stuff. The care package also includes a letter directing the blogger to include a CMP.LY URL in any coverage of the research via blog, Twitter, Facebook or otherwise. Bloggers log-in to CMP.LY with their campaign ID code to get their special URL for the program to use in disclosure.
  5. CMP.LY then creates a list for ExactTarget of all bloggers that have signed in, and monitors to make sure the disclosure URL is implemented. This gives ExactTarget a paper trail in case there is ever an FTC audit.

It all works very seamlessly. For instance, since I’ve talked about ExactTarget here, and they are a client of mine, I will disclose that relationship thusly:

There are 8 types of CMP.LY disclosures, governing most possible relationships (although CMP.LY type 0 is no relationship, so why disclose that?). There are versions for free samples, paid posts, co-marketing, etc. There’s even a custom CMP.LY if you’ve concocted some sort of “blog posts for body parts” scheme or something. a simple solution for required social media disclosures

CMP.LY badges

According to CMP.LY CEO Tom Chernaik, the company has an array of new features just around the corner, including visual disclosure badges to insert into blog posts. The badges (currently being beta tested by several big companies) provide a big edge because they create a valuable report showing how many times the blog post in question was viewed (the badges are javascript powered like the AdAge Power 150 badge below, not a static image).

This is of course a big win for agencies and brands, as existing data for trying to determine how many times a single blog post was viewed is massively flawed. Usually, only the blogger has the real numbers and he/she typically won’t share them with the promoting company.

“The real need is to document, not just disclose,” says Chernaik – who trained as a lawyer but no longer practices.

Brands will also be able to create custom badges for their programs, the way they can create special badges in FourSquare and Gowalla. This is a very nice touch for large-scale outreach efforts.

Recognizing that once you go beyond blogs brevity is critical, CMP.LY is also working on a “single link” solution whereby tweets and Facebook updates that merit disclosure can contain just one link (instead of the link in question + the CMP.LY link). This will be accomplished through a frame (similar to how HootSuite’s OW.LY links work).

Pricing for CMP.LY is free for bloggers or other social media types that want to disclose (as I did above). For companies, fees range from $200 per campaign, per month to $1000 per campaign, per month. The sliding scale is based on customization of badges, and API access.

My friend CC Chapman has been using CMP.LY for a long time, and has an interesting discussion of the system on his Managing the Gray podcast.

What do you think of CMP.LY? If you’re a blogger, will you start disclosing via CMP.LY? If you represent a brand, would you pay to use this service?




Facebook Comments


  1. says

    Completely unneeded. A service invented for people that don’t know enough to disclose their business relationships. I believe that if you are smart and above board you will have a big giant disclosure page on your site, and you will link to it from every page. If you are not above board then no service in the world is going to CYA.

    • says

      As a blogger, you’re probably right. From the brand perspective,
      however, the consistency and paper trail are significant advantages.
      And since the party responsible or compliance is the brand not the
      blogger, they’ll be the ones dictating what format disclosure takes.

  2. Randygiusto says

    This latest trends has pressured the blogging community but it is also befuddling the industry analyst community. Many analyst firms- Forrester, Gartner, IDC, Nielsen, NPD, etc. now have blogs embedded in their sites where they write about what’s going on. That includes companies. That includes companies that may be clients on custom projects, that either they are working on, or someone in their 1,000 person firm is working on. I will throw management consulting firms in here too because they are blogging more too.

    They don’t necessarily want to tell the competition who their client is. Many times they work on projects early on in the development process that the client forbids them to publicly say they are a client.So while a financial analyst can say “our company holds shares in X” when they are reporting on them, an industry analyst or a management consulting analyst does not.

    So I understand how the FTC is going after the bigger well known bloggers on this, but for the marketing research community, this is a big issue and I’m not sure that CMP.LY helps if the client does not want to be disclosed. It’s the equivalent of sharing your client list with the competition.

    For example, Apple does not typically work with market research firms so anything I write about them in a blog would get the none badge. But if I had a project with them on the next gen iPad, and I write a blog post about something else they do, would i be required to post the Business badge? If you do work with Apple, you are not allowed to say that you work with Apple.


  3. Raechelle says

    Whether they’re useless or not, thanks Jay for the reminder. Blogging can sometimes be an isolated task and many forget that there are rules governing social media and the internet. Great post.

  4. says

    Jay, I’m really confused about these rules. If I choose to write a blog post dissecting brand activity, where I have no relationship with the company (ie, if I write about something cool Moo Cards does, or why I think Apple is kiiling their brand with their ego) does that mean I have to disclose every time I mention a company whether I have a relationship with them or not? or just when I’m reviewing books, etc.?

    Can you clarify please? Thanks….!

  5. says

    Jay, excellent information. My main concern with CMP.LY has always been that I’m not certain it meets the FTC standard required for disclosure, which is ‘clear and conspicuous’.

    Besides the fact that the disclosure is not, in fact, on the blog but instead requires a reader to got to a 3rd party. Not only does the reader have to click a link but also then filter through the information which (1) does not tell the reader the site from where they came, until partly down the page, (2) uses the term ‘material connection’ which is a term of art used in the law which may not be understood by the reader and (3) requires the reader to go off the blog/site risking they may not come back to your site.

    Some disclosure is better than none. However, I’m not certain that this is ‘clear and conspicuous’ for the ‘average’ reader, as is the standard used by the FTC.

    • says

      It’s a good question. Thank you for the excellent comment. We’d all be
      better off if FTC faces us some clarity on the fine points, but that
      seems to be wishful thinking.

      • says

        OK, so…

        What’s the purpose in creating yet another profile on yet another website for the purpose of complying with government regulations — when the government doesn’t endorse the website? Seems like a waste of time.

        • says

          The government is not going to “endorse” any website, and for brands, this fulfills the disclosure and record-keeping requirements, which becomes pretty important if the government comes knocking.

  6. says

    I was actually writing up a proposal this morning containing a blogger outreach campaign for our potential client. I had to explain the FCC rule within the document. I think it would be worthwhile to use a service like It takes the manual process out of making sure that the bloggers are doing what they promised. Good post Jay.

  7. says

    With my travel blogger hat on, I’d probably say, “No thanks.”

    I disclose, clearly, in italics, at the end of every blog individual post that is the result of anything comped or client-related, I disclose on the Flickr and Facebook photo albums I may create from a comped trip, I mention periodically in my tweets that I’m on a sponsored trip, etc. I’m sure I’ve missed something somewhere, but I make every effort to meet the spirit, intent and letter of the law.

    All this other stuff is handy for my sponsor, and I probably wouldn’t categorically refuse to use some of it (need to look into it more) but they are getting free, high-quality content from me as a sponsored blogger, and to be terribly blunt, solving their tracking headaches is not my problem.

    Tracking is definitely an issue, but I’m not sure a new widget would help. Too many organizations wouldn’t know how to interpret my stats if I did share them (which I’m not shy about doing,) they often barely have Google Alerts set up, they don’t know when I’ve linked to them, they’re late to set up analytics before I get going producing content about them – and thus they have no baseline data – so a bunch of basic schoolhouse work still needs to happen there.

    There are ethics and cultural expectations and conversations here that go way beyond magic disclosure badges, and I’ve yet to find easy answers. I do appreciate the attempt to formalize the process, I guess, just not sure it works for me on the blogger end.

    In my consultant hat, I continue to beat the disclosure and tracking drums in client training, and this is certainly worth mentioning.

    • says

      I hear you. At some point it seems much ado about nothing. But as I replied
      to an earlier comment, the driving force behind CMP.LY (or any program like
      this) will not be the bloggers, but the companies involved. Is CMP.LY early
      to this game, so much so that some companies (like the ones you’re covering,
      it sounds like) don’t know what do do with it? Absolutely. But remember that
      Google Analytics (which we now take for granted) was actually developed
      almost a decade after analytics were first on the scene.

      Early doesn’t mean invalid. And all it will take is ONE major “bust” for
      companies to begin demanding that bloggers begin using a solution like this

  8. says

    You posted some great information today, something bloggers and copywriters etc. should be aware of. Also, the points Sara at Saving for Someday brought up were interesting too. I don’t like the idea of sending someone away from a blog to a third party site. How many readers do you suppose are going to click on a disclosure link then actually read the information provided? An upside to the situation – I do like the idea of the “visual data badge.”

    • says

      I think once they have the badge, and the badge makes it clear what the nature of the relationship is, the clicking through part becomes superfluous in most cases. How often do people read “privacy policy” “terms of service” or “creative commons” pages that are a click away? You see the link, and you make corresponding assumptions.

  9. Jerilyn says

    Very interesting…I will have to bring this to the attention of my company. I’m new at blogging and wasn’t aware of this. Thanks!

  10. says

    So when I tweet, in order for me to comply with FTC, I would have to include cmp shortlink AND that takes a follower to the actual post? Or am I way off on this one?

  11. says

    That’s the idea for now, until CMP.LY rolls out their single link solution, which of course will be much easier, as 2 links chews up a lot of characters.

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