how much do you pay a shill with an audience to bark your goods
Correct, that is the question. There is nothing rude in your characterization.
To put it in more detail... We don't have editorial control or control the number of tweets. We offer product to people we hope are influencers and we hope they will like it and will tweet, post, blog about it.
In theory, that could lead to a bad review. In practice, most of these people are professional shills. The ones who are what we used to call "journalists" back in the age of dinosaurs refuse the free product. Those reviewers are commonly barred by their employer from accepting anything for free from us.
For the others, though, they know that if they post a lot of bad reviews, they won't get any more free stuff which in most cases is the whole reason they started blogging/tweeting/facebooking in this niche. Which ultimately means their readers know the reviews are fluff pieces, which leads to low engagement which leads to low value to me which leads to me pushing my colleagues to have much stricter standards for who gets free stuff... and this question is part of my quest.
have a 7-10% interested audience
For the reason mentioned above, I'd question that for a lot of these people. We try to compare engagement metrics (comments, retweets, @messages), but that's hard both in the sense that it's work and in the sense that a lot of the retweets are also interested parties (other writers for the same site would be one such case).
For me, the simplest metric is to estimate how much we would have to pay for the same exposure and ask: do we spend this on free swag, promoted posts, or Google AdWords. The one difference being that if the person does become a genuine fan, there is the chance of repeat tweets, blog posts (and thus links), so the value is a bit different than an AdWords campaign where it stops entirely once it dries up.
We recently, for example, had an article published by a major metro TV station blogger who after getting pitched by us and getting her station to pay for free-to-her stuff started following us on social media and really liked one of our Facebook posts. She made our FB post and a similar one from someone else in the same niche the core of her short blog article and as a result, a post that took a colleague and I under 30 minutes to plan, film, edit and post got hundreds of likes and had a reach of something like 25,000 (our third highest of the last 6 months). So there are long-term follow-ons from some of these arrangements.
Does the FTC guidance on revealing the paid status of a blog post apply to tweets?
Since 2013, yes:
Announcement: [
ftc.gov...]
Updated Guidelines: [
ftc.gov...]
You can satisfy this requirement with the #ad hashtag and it MUST be included in the same tweet. It can't be in back to back tweets for example.
In terms of free swag where the person is not being paid to tweet but given free stuff in hopes s/he will tweet, it's less clear but I think this would do it: "Loving the Road Runner Buster that Acme products just gave me" would, I think, fulfill the FTC requirements. Something like #comp or #freesample would work too. In our case, many of these people just get a discount, so that's another issue. I'll also say that the vast majority of people who blog about products in our niche do not disclose.
Even worse, the requirements are fairly fuzzy. This is from the FTC FAQ on the subject:
A famous athlete has thousands of followers on Twitter and is well-known as a spokesperson for a particular product. Does he have to disclose that he’s being paid every time he tweets about the product?
It depends on whether his readers understand he’s being paid to endorse that product. If they know he’s a paid endorser, no disclosure is needed. But if a significant number of his readers don’t know that, a disclosure would be needed. Determining whether followers are aware of a relationship could be tricky in many cases, so a disclosure is recommended.
src: [ftc.gov...]
So in other words, Serena Williams does not have to disclose in her tweet about a new Nike shoe, but if Nike gives me shoes, my tweet has to say they were free.