Changes to Facebook Promotion Guidelines: “LIKE” It or Not?
Facebook Post: “Win a $100 shopping spree to our new store! To enter, simply ‘Like’ (fan) our Page and leave a comment about our fall fashion line. We’ll pick a winner at 1pm EST tomorrow.”
Until recently, a simple Facebook posting like this would have violated Facebook’s promotion guidelines and would have subjected the sponsor who made the post to possible shut down of its Facebook Page (“Page”) and related legal complications. For social media-savvy businesses, Page shut down means cutting off access to the vast Facebook community, wasted resources, and potential negative buzz in the marketplace. On August 27, 2013, Facebook updated its terms governing the use of Pages (often referred to as the “Guidelines”) for brands, entities, and public figures to explicitly permit the communication and administration of promotions, such as a sweepstakes or skills contest (“Promotions”), directly on the Page. Previously, all Promotions conducted on Facebook had to be administered through a third-party app run on Facebook’s platform.
“Like” It or Not?
In light of the recent changes, a sponsor may now administer Promotions directly on its Page, through a separate app, or both. The best way to launch a Promotion on Facebook depends on the goal of the Promotion as well as the resources and time allocated to it.
Launching a Promotion with an app on Facebook allows for a more personalized experience for participants, which in turn may make for a more effective branding strategy. Apps also provide more flexibility and space to promote and advertise the Promotion than Page posts alone. Apps may also facilitate secure data collection from participants. On the other hand, launching a Promotion with a Page is faster, easier and less expensive.
Requirements for Administering a Promotion on Facebook
Promotions may be administered only on business Pages and cannot be run on personal Pages. The rules for running a Promotion on a Page include the following:
- Promotions may now be administered on Pages or within apps on Facebook, but not on personal Timelines. For example, sponsors can now:
- Collect entries by having users post on the Page or comment/like a Page post.
- Collect entries by having users message the Page.
- Promotions cannot require that entrants take any action on their personal Timelines (e.g., post content on their Timeline) or require that entrants tag themselves in photos in which they do not appear.
- Promotions on Facebook must include the following:
- A complete release of Facebook by each entrant or participant.
- Acknowledgement that the promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook.
- Sponsors are solely responsible for the lawful operation of the Promotion under federal and state laws.
Takeaways for Sponsors
Even though recent changes to the Facebook Guidelines have made it much easier for sponsors to launch Promotions directly on Facebook, Promotions must still meet all of the Facebook Guidelines described above as well as applicable state and federal laws. Other social media platforms also have rules for Promotions that change from time to time. Therefore, when in doubt, sponsors should seek legal advice before launching a Promotion to ensure full compliance with all applicable laws and social media rules.