Without clear industry guidelines against deceptive efforts, how can up-front word-of-mouth marketers differentiate themselves from the shills?
The term "buzz marketing" denotes a section of the marketing mix that has as many definitions as it does practitioners. Many involved say that buzz marketing, word-of-mouth marketing, and stealth marketing are three separate and distinct fields that should be recognized as such. But to the public - as well as to activist groups - the distinctions are not clear and meaningful. And that is part of the reason that the field finds itself in the midst of controversy as the PR industry and corporations struggle to define where it fits in the larger world of marketing services and what guidelines should exist to professionalize the diverse discipline.
The need for standards was brought into sharp focus on October 18, when Commercial Alert, a nonprofit that works to curb commercialism aimed at kids, sent a letter to the Federal Trade Commission calling for an investigation of the industry. The letter read, "There is evidence that some of these companies are perpetrating large-scale deception upon consumers by deploying buzz marketers who fail to disclose that they have been enlisted to promote products," a practice deemed "fraudulent and misleading."
The group says that failure to disclose these relationships might violate the section of US law dealing with unfair or deceptive commercial practices.
Gary Ruskin, Commercial Alert's executive director and author of the letter, says he was prompted to start tracking buzz marketing several years ago, as examples of undercover campaigns began popping up in media stories. He says he simply wants the government to enforce existing laws, which he feels are being exploited by the buzz marketing industry.
"Self-regulation of advertising has a long history of failure," he says. "We have laws prohibiting deceptive advertising here in the US. If companies break the law, they have to face the consequences. ... The issue here is, shills have to be disclosed [as] shills."
Buzz versus stealth
Commercial Alert has had success in the past targeting issues like search-engine ads and market research in schools, and its buzz marketing effort has drawn a fair amount of major coverage. But the buzz industry is seeking to put the word out that it agrees with many of the group's feelings regarding disclosure, and that it is working to address the issues from the inside.
"Anyone in the word-of-mouth marketing business has been opposed to stealth and deceptive marketing from the beginning," says Andy Sernovitz, CEO of the Word of
Mouth Marketing Association (WOMMA). "Our only concern is they use the term 'buzz marketing' as a generic term."
To Sernovitz, "stealth" marketing is buzz without the disclosure. But others, such as Ruskin, use "buzz" as a catchall.
Sernovitz says that Commercial Alert should be clear that its complaint refers to stealth marketing, which would dovetail with WOMMA's code of ethics. That code calls for blanket disclosure during word-of-mouth campaigns in the form of "Honesty of Relationship, Opinion, and Identity." It states that members should comply with all relevant FTC regulations (specifically citing those dealing with disclosure and honesty when representing consumers' opinions), and says, "We stand against shill and undercover marketing, whereby people are paid to make recommendations without disclosing their relationship with the marketer."
While Sernovitz says that he has no "real fear of regulation at all," he adds that it is crucial for the industry's ethical practitioners to assert themselves, lest the entire industry be lumped in with its worst elements.
"Having a positive, strong, word-of-mouth marketing industry fighting against deceptive stealth marketing is how a solution happens," he says.
WOMMA's membership includes a variety of marketing and PR agencies, as well as corporations that are believers in the practice. One firm on the vanguard of the movement is BzzAgent, which drew attention when its methods were profiled in a New York Times Magazine article this year. Joe Chernov, BzzAgent's PR director, echoes Sernovitz's support for the spirit of Commercial Alert's effort and similarly takes issue with what he believes are its loose designations.
"We require all of our agents - who are volunteers, unpaid - to disclose their affiliation with us and the brand we represent," he says. "We require them to be proactive in the disclosure."
In fact, Chernov is currently working on a white paper that makes the case to clients that disclosure offers a practical business value above and beyond its ethical value. "Are campaigns more effective [when they] have disclosure?" he asks. "I'm discovering that the answer is yes."
Codes of ethics
Major PR firms, mindful of industrywide disclosure issues brought to light this year by the VNR and Armstrong Williams controversies, are among the biggest backers of WOMMA and its attempt to codify ethical standards. Burson-Marsteller, one of WOMMA's governing members, has entered the buzz marketing space via the internet with its "e-fluentials" survey of online influencers. Idil Cakim, Burson's director of knowledge development, says that firms involved in word-of-mouth marketing need to steer clients in a healthy direction.
"I do believe there's a distinction between organically grown word-of-mouth, where ... trendsetters pick up on it and talk about it. And then there's the other sort of marketing, where you create a scenario and engage people in it," she explains. "At Burson, we always advocate for organic word-of-mouth. The work should speak for itself."
Rick Murray, an Edelman EVP who heads the company's "street marketing group" and is a WOMMA member, says the group's attackers are late to pick up on a marketing practice that has been going on forever, but one that should not define the entire industry.
"In the association, we spent and invested a lot of time coming up with a code of conduct that we thought people could and should live by," he says. "Some companies will choose not to follow those rules, or [will] interpret them in a very loose way. And, honestly, those are the folks that are going to get the industry in hot water."
Murray doesn't believe the word-of-mouth industry needs to mount its own PR push yet, but he does say that ethical violators should not expect agencies with strong ethical commitments to save them out of a misplaced sense of all-for-one.
"The code of ethics is out there," he says. "The companies that interpret it in a very gray way are asking for some kind of campaign against them, whether it be through a third-party organization or the government."
One group singled out in Commercial Alert's complaint is Tremor, the buzz marketing arm of Procter & Gamble that targets teens. Tremor is not a WOMMA member, although its 250,000-strong force of young buzzers certainly makes it a force in the industry. And contrary to WOMMA's guidelines, Tremor doesn't require its teens to disclose who they are working for. "We don't require them to communicate that Tremor is part of the information that they're talking about, but we don't dissuade them from saying it either," says P&G spokeswoman Robin Schroeder.
She said that P&G is waiting for the FTC to contact it regarding the issue. Tremor is in touch with WOMMA, she said, but has not made any move to join.
Many corporations, however, subscribe enthusiastically to WOMMA and its ethical code. Cold Stone Creamery, an ice cream retailer with 1,200 US stores, joined the group earlier this year because of the company's commitment to grassroots PR and word-of-mouth. Coldstone PR director Kevin Donnellan says buzz marketing will only continue growing because its ability to appeal to consumers directly is unrivaled.
"As consumers, we're inundated with meaningless commercial ads," he says. "Having more interaction with products, services, and people, I think, is exactly what consumers want. It's unfortunate that some of these practices have begun to be looked at under a microscope."