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Did you hear the latest in corporate social media debacles? Cole Haan, purveyor of fine footwear, hosted a Pinterest contest that caught the attention of the Federal Trade Commission -- and not in a good way. Here's the low-down on what happened, and how to avoid making the same mistake that Cole Haan made:
The 'Wandering Sole' Contest
If you're not familiar with Pinterest, it's another form of social media where people essentially create online mood boards consisting of everything from recipes, to shoes, to home decor. Understandably, many brands' marketing departments have turned to Pinterest as a way to attract existing and new audiences.
Cole Haan hosted its "Wandering Sole" contest, which called for contestants to create a Pinterest board and pin five of their favorite Cole Haan shoes, with the #WanderingSole hashtag, for a chance to win a $1,000 shopping spree, according to MediaPost.
The FTC's Letter
On March 20, the FTC sent Cole Haan's attorneys a letter stating that the FTC was investigating whether Cole Haan's Wandering Sole contest violated the Federal Trade Commission Act. The problem? The FTC saw the contestants' pins as "endorsements" and that the pins did not make it clear that they were for a contest. The letter added, "We do not believe that the '#WanderingSole' hashtag adequately communicated the financial incentive -- a material connection -- between contestants and Cole Haan."
Despite that, the FTC chose not to pursue enforcement action for three reasons:
Tips for Brands on Social Media
So how do you avoid the wrath of the FTC? Based on the letter, we've learned a few things:
There is by no means a road map when it comes to social media because of the constantly changing digital landscape. That said, it's always best to take the safe route. To do so, make sure that the legal department stays up to date with changes in social media, and how your company is interacting with its customers.