For every claim an advertisement makes there should be a disclosure. A disclosure is additional information that a consumer should know about the claim. On page four of the Federal Trade Commission's March 2013 report "Dot Com Disclosures", disclosures are important to make sure that advertising is truthful and not misleading, advertisers have evidence to back up claims, and advertisements are not unfair.
Consumers are used to disclosures on medical commercials on TV that say things like side effects may include dizziness, diarrhea, vomiting, etc. Here is an example for the drug Lyrica.
But disclosures are not just for TV commercials or ads on magazines, digital ads also need to follow the FTC guidelines. Digital media ads have more variety for example ads can be in webpages, on banners, on mobile devices or they can be pop ups. An ad can be a tweet but it might need a disclosure even though it's only 140 characters.
Can't Fit the Disclosure? Don't Make the Claim!
Twitter is not the only place that has a limited space. Facebook has limited space too and so do banners. A lot of advertising is through banners. Banners are usually graphics or animation and it's hard to put a disclosure there without making them ugly. On page fifteen of the report the FTC said that a disclosure should be next to the claim even in the banner or it should be displayed clearly on the linked page.
Here is a rich media banner created by Sara Peterson Designs that shows a disclosure for the claim that if a customer buys a premium salad from McDonalds they can get a free week at the New York Sports Club.
The disclosure is in small text in the lower left hand corner of the banner and says that there is a limit of three 1-week memberships per customer. If a customer doesn't see the disclosure, they might think that they can eat a McDonalds salad every week and get free gym membership for a year.
Different Platforms in Digital Media
Another issue with digital media is that it doesn't appear just in one platform. TV commercials are on TV, magazine ads are in magazines but digital ads can be on desktop computers, laptops, tablets, and on smartphones. The FTC report showed an example of a webpage that had an advertising claim in the middle column and the disclosure in the left column. When the same page is viewed on a smartphone and the customer zooms in to read the claim, the disclosure disappears.
Advertisers should have in mind what platforms their ad will be shown on and create different versions for different platforms. For example the McDonalds happy meal website solves this problem by creating an mobile version of the site.
Because there is a game on the webpage, McDonalds added a disclosure in the upper left hand corner saying that the entire webpage is advertising.
The disclosure is even more clear on the mobile version and appears at the top.
Hyperlinks and Disclosures!
It's better to have the disclosure next to the advertising claim but if the disclosure is too long it can be hyperlinked near the claim. According to the FTC report on page ten, hyperlinks should only be used if the disclosure is not integral to the claim.
On McDonalds main happy meal page I found what I thought was an advertising claim but there was no link.
I went to the McDonalds nutrition page for happy meals and found what I thought was another claim and there was a link.
But when I clicked the link, it didn't bring me to a disclosure explaining why their quality and safety standards are higher than most of the restaurant industry. The link actually went to a page that was mostly advertising. This might not be a claim legally but as a regular consumer it seems like a claim that should be supported by a scientific study.
Disclosure Is Important!
We can see that having disclosures are even more complicated in digital media than traditional media. Disclosures in digital media are as important as any other media because they are still required according to the FTC. Digital advertisers should keep in mind that a claim in cyberspace is the same as a claim anywhere else.
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