It’s been a long process moving things to the WorkAtHomeTruth store, but it seems to solve a lot of problems in one fell swoop.

Note, I’m not an attorney, so get your own legal advice on how to implement your own material connection disclosure.  I did however provide a tremendous amount of documentation to the FTC on one of their Operation Shortchange cases (FTC v. In Deep Services) that involved disclosures (although not affiliate disclosures) and spent a significant amount of time on the phone with one of the senior litigators there (and ultimately agreed to testify in the case). 

I also had significant involvement in helping consumers file complaints and recover money (at no charge to them) on two of the other Operation Shortchange Cases, including Google Money Tree (National Consumer’s League used a lot of my write-up and blog discussion here).

Again, I’m not an attorney, though. Also, this only applies to links within your OWN site – it doesn’t apply to affiliate links on forums, social media sites, etc.

So here’s what we’ve done (we are still in the process of moving items to the store):

First of all, at the top of product reviews now we do the following:

1. Explain the reviewers connection to WorkAtHomeTruth (i.e. Product reviewer for WorkAtHomeTruth)
2. Immediately disclose that the product is “Available At The WorkAtHomeTruth Store” – i.e. it is OUR store and it generates income for WorkAtHomeTruth - whether from products we own or ones we recommend as an affiliate.

You can see an example of how this works here:

http://store.workathometruth.com/atomic-blogging-review/

You’ll also notice that based on the header you are clearly in a “store section”.

Plus when you click on any of the links on the review you have to go through the product page at the STORE to buy (through an “Order Now” button).

Here are all the problems and affiliate issues this solution solves.

1.  Inline disclosure of material connection in a way that is natural. Many affiliates have started putting affiliate link disclosures after every single link they post in their blog. As

By having a “store” section there is clearly a material connection between the site owner and the product they recommend.

I’ve actually found it odd that Brian Clark’s disclosure for the book Desperate Buyer’s Only here has often been hailed as a great example of affiliate disclosure. It’s OK. But there are definitely problems.

First of all, the disclosure comes at the END of the review AFTER other non-disclosed affiliate links within the text. Anyone who’s ever tracked clickthrough rates on their affiliate reviews knows that usually a decent percentage of the clickthroughs happen in links before the end of the review. So a person clicking on one of those links may have no idea about the affiliate relationship.

Admittedly this is “nitpicking” since the FTC clearly states that they evaluate the “entire mosaic” of the advertising message as well as what a “reasonable consumer” is in the circumstances not to mention a whole host of other factors the FTC would look at.

However, the system I recommend puts the disclosure at the TOP of the review and inline on EVERY link (which is NOT an easy task if you have an existing large site – we are STILL moving a lot of items into the store).

Some might argue that doing so disrupts “the flow of the copy”. That was an old argument made about affiliate disclosures.

Obviously, there needs to be more test data to know for sure. But if the OTHER big argument affiliate’s kept making a few years ago about why they didn’t use disclosures is true – namely that “our readers know we are affiliates and they are loyal followers and they don’t care” – then what harm can there be in including a simple disclosure at the TOP of the review?

If they are such raving fans and don’t care about your affiliate status they won’t care if you disclose at the TOP of your review will they?

2. Moving the visitor through a store makes it hard for them to “miss the point”.

I found the following statement at Shawn Collins’ AffiliateTips.com curious:

“By the way, I put up an affiliate link disclosure on my blog (with a link in the header) quite some time ago, and nobody – literally nobody – ever goes to that page.”

Sure, that could mean that nobody cares about affiliate disclosure statements. It could also point to that being a bad way to disclose affiliate relationships.

In fact who is best able to determine how effective a disclosure policy? Why the person controlling the site analytics that can give data as to the effectiveness. I was unable to dig up the reference, but I seem to recall this being discussed in the FTC workshop on negative option marketing in 2007.

Marketers spend an enormous amount of time and resources testing copy and monitoring it via analytics. So to apparently come to the conclusion that “nobody cares” about disclosure statements without testing various placements seems a bit disingenous.

3. I can make natural recommendations on my blog and send them through a review that then sends them through a store.

If you control your blog one issue that comes up is people asking you for advice about products.  I do recommend products that don’t benefit me materially (although they do increase my “trust factor” so as Jack Humphrey’s points out in this discussion typically linking to anything off site does involve some sort of self-serving principle).

But I can also link them to a review on the site that discloses the affiliate relationship at the top – and then moves them through the site store.

To me this seems to be more akin to a person’s natural buying process in the offline world – they go to a consultant/sales person who then analyzes their situation and ultimately receives value (usually money) in exchange for consulting that person and finding a solution for them based on their circumstances.  (As an aside: non-individualized “Top 10 Lists” can still serve some purpose if they are based on overall site demographics – admittedly not a perfect solution).

Not only that, most people aren’t used to bying through a “compensated affiliate link” – but they are used to buying through a store.

It’s just seems more natural to have a store in almost every conceivable way.