Facebook’s New Promotions Guidelines – How Do They Affect Your Business?
11/09 2PM Update: Our Facebook account representative has confirmed that all Promotions must be run through a third-party application, meaning Facebook’s own Static FBML app is a no-go.
Last week, Facebook published its new Promotions Guidelines, covering rules and regulations for all kinds of sweepstakes, contests, and giveaways hosted on the Facebook platform. Among the most important revisions to the guidelines (helpfully highlighted in Inside Facebook’s post from Friday) are Facebook’s new “written approval” requirement and prohibitions against use of the wall, status update, or commenting features in any publicized promotions.
According to Section 3 of the new guidelines, in order for any business to run a promotion on their Facebook page, they must first acquire written consent from an account executive at Facebook. If you represent a business that is marketing through Facebook and do not yet have an account representative assigned to you, you can apply for one here. Of course, requiring a written approval necessarily implies additional time requirements, meaning that you will have to have all aspects of your promotion ready for review well before your planned launch date (7 days in advance, to be exact).
Rather than utilize Facebook’s built-in status update and commenting features, businesses are now explicitly required to host any and all promotions via a separate application. That application can either live on the Boxes tab of a business’s fan page or on its own separate canvas tab. While Facebook does not specify whether or not this application must be a third-party application in Section 3, it does refer solely to third-party applications in its examples of “can”s and “cannot”s in its post-script explanation of Section 3, which implies that to run applications via free Facebook-developed applications like Static FBML may also be off-limits.
For the most part, I think Facebook’s revisions to the Promotions Guidelines are a positive thing for everyone. But it’s still unclear exactly to what extent these new guidelines will affect small businesses as opposed to large businesses. At the least, I would imagine that the vast majority of small businesses testing the Facebook marketing waters do not have in-house lawyers to turn to for help with the drafting of official promotions rules, which would likely be helpful in gaining written approvals from Facebook. Larger companies will naturally be at an advantage in this area – but frankly, that isn’t saying much as anyone with a significant ad budget is going to have the advantage over the corner store. What concerns many of us here at theKbuzz is specifically how Facebook’s new written approval process might affect small businesses with limited resources. Is Facebook prepared to handle a potential deluge of requests for Promotions approvals? Are provisions in place to ensure that approval requests are managed on a first come, first served basis regardless of budget?
In general, I’d like to see details about the approval process fleshed out more thoroughly, as the current process is a bit hazy. Will a business be expected to twiddle its thumbs waiting for a clear yes/no from its Facebook account rep and then have to reapply beginning another 7-day wait period, or will it have the opportunity to make all suggested revisions during that approval period? I’m also not a fan of Section 6.1 detailing Facebook’s right to “modify these Promotion Guidelines at any time without notice to you. You will subject [sic] to the most current version of these Promotion Guidelines then in effect.” I believe that if Facebook is truly committed to serving its advertisers, marketers, and application developers, its employees would benefit from keeping their clients up-to-date on the latest developments to ensure that everyone is similarly legally protected and prepared. We’ll be doing our own part to make this process as simple for our clients as possible – what are your concerns regarding or suggestions for improving Facebook’s new Promotions Guidelines?
– Devin Sugameli, Director of Buzz @ theKbuzz
Great post, Devin. I guess my biggest concern is do you HAVE to be an advertiser to get a promotion approved? and how do you go about getting an account rep. If you go through the site as it says, if you say your budget is less than $10K it basically says you are better off to do it yourself.
my other concern is on the pre-approved third party vendors. Is there profit-sharing going on between Wildfire and Facebook?
I do agree with you in that it will be better for the greater good but it sure is gonna stink for the small guy!
Hey Dave – as you know I published my own spin on these new Promotion Guidelines too, and I feel a wee bit sorry for the small biz peeps. Nonetheless, I’m all about creating buzz through relationships and creative out-the-box low-cost ways anyway. Not being able to run contests/competitions on Facebook isn’t all that big of a deal in the grand scheme of life and social networking. LOL!
I know you fine folks at theKbuzz do super buzz marketing strategies too and so, for the most part, these new guidelines just challenge us to get more creative *and* more integrative in our approach to marketing/social marketing period. 
Marissa – To be perfectly honest with you, I hadn’t gone through the Contact Form myself until just now. I would have thought there would just be different levels of account representatives assigned to each group! You might be even more surprised to find that the $10,000-24,999 anticipated monthly budget level also brings you to the “do it yourself” page you mentioned. Basically, I think this confirms my concern that Facebook wouldn’t be prepared to handle a potential deluge of requests. I’d suggest to Facebook that the trade-off should be a quicker/simplified approval process for less “face” time with an account rep. Hopefully this is something they plan to address sooner than later.
Mari – I’m concerned for smaller businesses, too! While we are happy to be able to offer solutions to our own small business clients, we also want to know that they will be able to apply what they learn on their own if they so choose. You’re right about stepping up to the challenge to be more creative though – never a bad thing
Devin,
I have a couple of questions about the new regulations…
1) It seems like FB is defining promotion only as a contest or competition – in other words users/fans are vying against each other for a prize or reward. Do you know if the guidelines apply if a company makes discounts/offers available to anyone, so long as they jump through certain hoops (e.g. joins a fan page, goes to a landing page, completes a form, invites friends, etc.)
2) Assuming all promotions apply (not just contests and competitions), the guidelines say you cannot require a user to undertake an action on FB to qualify. What if the promotion conditions are only published on a fan page. In this case, you don’t need to join the page to qualify, because the only way to learn about the promo in the first place is if you are already a fan.
I’d greatly appreciate your thoughts.
Cheers,
Jon
Devin,
(sorry for duplicate comment – my wife didn’t log out)
I have a couple of questions about the new regulations…
1) It seems like FB is defining promotion only as a contest or competition – in other words users/fans are vying against each other for a prize or reward. Do you know if the guidelines apply if a company makes discounts/offers available to anyone, so long as they jump through certain hoops (e.g. joins a fan page, goes to a landing page, completes a form, invites friends, etc.)
2) Assuming all promotions apply (not just contests and competitions), the guidelines say you cannot require a user to undertake an action on FB to qualify. What if the promotion conditions are only published on a fan page. In this case, you don’t need to join the page to qualify, because the only way to learn about the promo in the first place is if you are already a fan.
I’d greatly appreciate your thoughts.
Cheers,
Jon
Hi Jon!
Facebook is indeed defining a “promotion” as a sweepstakes or contest. Coupons and discounts that are freely available to ALL fans are not subject to the new Promotions Guidelines. You can also hide the coupon or discount under a “fan-only” code. As long as you do not require fans to “jump through hoops” as you said above, you’re golden! Hope this helps =)
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Well I understand facebook’s concern, but as someone who has just spent my year’s ad budget on an ad in October which will be published in December and has gone to press already, I feel really caught. I wish I had just spent the money on advertizing on facebook compared to the hassle it will be for me to try to run it on another platform.
Thank heavens I didn’t point entrants directly to facebook….I’m sure there must be some people who place ads earlier this year who will now find themselves in this position.
Devin – How confident are you in your statement that freebies are fair game? What in the promo guidelines says that? I’ve been trying to find that info and yours is the only post that suggests it is (I hope you’re right, but want to verify). I run the Page for a movie theatre chain and want to offer free film nights to our Facebook fans just by printing a Note, but want to make sure it qualifies first.
Jeremy, we have confirmation from Facebook that as long as you word things correctly, as a coupon code for instance, you can do ‘freebies’ from Page tabs.
Thanks, Helen – Does it have to be in a Tab? What if we said “print this Note and bring it in for a free appetizer?” It’s a promotion, but it’s open to everyone (not a contest) and does not depend on providing content. Wouldn’t that still be valid?
No. 3rd party Tabs. Not Notes, Jeremy.
Dave – Can you explain why? We’re looking at giving something away completely free to anyone who prints it out. There is no entry required by the user and no action to be taken (except printing). It’s not a contest.
It would be valid to update our status with a link to the freebie on our website, so why is it different if we published a Note instead?
Just use FBML, Jeremy- I’ll tell you what – Call our office and I’ll do this one for you for free
718.416.2899
Are free giveways considered “promotions” if you participants are required to become a fan to get the freebie? There is no prize drawing or winner. Everyone gets the freebie.