PBS and its editorial partners occasionally pay or otherwise provide consideration to social media influencers to promote PBS content. While there is nothing inherently wrong with this practice, the audience should never be misled about the nature of such promotions.
The PBS Editorial Standards set forth transparency as a core value. As such, influencers who have a connection with PBS must disclose this fact so that the audience can "evaluate the credibility of the work and determine for themselves whether it is trustworthy.” This disclosure also ensures compliance with the Federal Trade Commission’s laws and regulations on deceptive and false advertising (15 U.S.C. §§ 45(a), 52).
This disclosure needs to appear wherever the influencer promotes PBS content—e.g., if the influencer promotes content in a video posted on Twitter, the disclosure should appear at the beginning of the video and in the tweet accompanying the video.
A disclosure also should appear in every social media post where an influencer promotes PBS content. Influencers should not assume that the audience saw any of their prior posts or disclosures.
Finally, the disclosure must be clear and conspicuous. PBS requires that:
(1) The disclosure language must be unambiguous. The disclosure should be straightforward and easy for the audience to understand.
- Social media text should include an unambiguous hashtag such as “#ad,”“#sponsorship,” or “#paidpartner.”
- Video scripts should include unambiguous language such as: “This is a paid partnership with PBS,” or “This video is sponsored by PBS.”
(2) The disclosure must be conspicuous. The audience should be able to easily notice the disclosure without having to look for it.
- Consumers viewing posts in some social media feeds (e.g., Instagram, Facebook) typically see only the first few lines of a longer post unless they click “more.” Influencers should ensure that any required disclosure appears in text above the “more” link. Consumers should not have to click “more” to see the disclosure.
- A disclosure appearing in social media text should not be mixed in among other hashtags or handles, or otherwise buried amid various hyperlinks, because the audience would then have more difficulty noticing the disclosure. For example, “#ad” should stand alone at the beginning or end of the text (not included in a string of other hashtags).