Join us for a 30-minute webinar on July 15th from 2-2:30pm EST where we dive deeper into Incentivized Ratings & Reviews Best Practices. Register here or contact us for more information.
Background on incentivized reviews and the consumer protection requirements
Incentivized reviews are a fundamental part of the marketer’s tool kits – and for good reason. Most Canadians shop online, and over 90% of them have searched for reviews in the process. Moreover, 74% say they search online reviews before making in-store purchases. In short, consumer reviews have an enormous impact on whether a product is successful or not.
Because of this, incentivized reviews fall under the purview of the Competition Bureau. The Bureau is responsible for ensuring that consumers can trust reviews, and that advertisers are not providing misleading information. At present, the key criteria for identifying a false review is if advertisers incentivized it and the material connection is not clearly and prominently disclosed and described. The Competition Bureau has also published numerous digests that provide clear guidance on what they are looking for with regard to organic reviews, including a focus on genuine, impartial reviews for real customers that include both pros and cons of the experience. These principles should be applied where possible to incentivized reviews as well.
Simple standards meet a complex web of different approaches
While that may sound straightforward, the reality marketers face today is far more complex because of multiple and inconsistent standards across the major players. Furthermore, this puts the marketers at risk of unwittingly running afoul of the regulations, even if there is no actual intent to provide “false reviews”.
Retailers such as Amazon, Walmart and Costco are the primary locations where consumers search for reviews, and these retailers control their own sites. Consumers also find reviews via Google which pulls reviews from retailer and brand sites.
Retailers often request that brands ensure products have a certain minimum number of reviews, which then triggers advertiser-sponsored programs to generate incentivized reviews. Bazaarvoice and PowerReviews are technology platforms that allow single product reviews to be “syndicated” across multiple retailer sites, which is a huge benefit to advertisers.
These technology platforms along with the retailers have set the disclosure standards and standard practices for the collection and dissemination of these reviews, often adopting policies developed in the USA.
To make matters even more complex, Amazon has their own incentivized review program, Amazon Vine, where companies pay Amazon to obtain these reviews that coexist alongside other reviews. In addition to the retailers and review syndication platforms, advertisers will also engage third party agencies such as Shopper Army (affiliated with BrandSpark and Best New Product Awards) to help them generate these incentivized reviews.
Inconsistent standards are being applied in Canada when it comes to the generation of the reviews, as well as the disclaimers that are applied. In marked contrast to sponsored influencer programs where advertisers and agencies follow Ad Standards Disclosure Guidelines, there are currently no similar Ad Standards guidelines for incentivized reviews.
There are many forms of incentives that might be provided to consumers, including: free products, discounts or rebates, entries into sweepstakes, and compensation. Sometimes a consumer is provided with a full-sized product, sometimes they are only provided with a sample of the product. Currently the standard incentivized review disclaimer used most often is “this review was collected as part of a promotion” and it is usually found at the beginning of a review if syndicated via the Bazaarvoice network.
BrandSpark’s recent Consumer Endorsement Trust Study revealed that this disclaimer on its own is not clearly understood by consumers and does not provide an adequate disclosure of the material connection.
There are other ways for incentivized reviews to find their way onto retailer product pages, and consumers may come across reviews pulled by Google where disclaimers may also not be sufficiently visible. As well, this standard disclaimer is generally not adjusted to reflect the different forms of incentives.
Advertisers are not meeting current consumer protection standards
When seen all together, we don’t believe that current practices being followed by most advertisers meet the standards required under Canadian consumer protection laws. This leaves advertisers exposed to possible fines and reputational harm.
Advertisers need to exercise more control over incentivized review programs as they are the actual sponsors of the programs and therefore the ones that could be held responsible. Separate guidelines are necessary to ensure that these incentivized reviews can be trusted by consumers and ultimately the regulatory authorities. The current Ad Standards Influencer guidelines follow the correct principles but do not specifically address incentivized reviews. Given the strict rules set out by the Competition Bureau, it is advisable that Canadian reviews (and not those imported from the USA or other countries) are obtained and that they follow the strict guidelines that are expected in Canada.
How Shopper Army can help
Shopper Army has developed a new Incentivized Review procedure to collect quality authentic reviews that can be trusted and that properly disclose the material connections. This includes an easy to understand disclaimer that must appear at the beginning of each incentivized review and is customized to the specific type of incentive. This transparent approach clearly discloses the material connection. As well, Shopper Army product testers are recruited with clear instructions to ensure that real experiences are shared by requiring actual use of the product has occurred and pros and cons are shared with sufficient detail. Of course, it is also important to ensure that all reviews are shared and that any filtering out of negative reviews is strictly forbidden. Shopper Army’s new Trusted Review badge is another way that consumers, advertisers and regulators will know that the strict requirements to protect the integrity of online reviews has been followed.
For more information about the BrandSpark® Consumer Endorsement Trust Study or the Shopper Army® Best Practice Guidelines for Incentivized Reviews, please contact Robert Levy at BrandSpark.
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